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Category: Direct Exam

DIRECT EXAM OF A CLIENT WITH A BRAIN INJURY

DIRECT EXAM OF A CLIENT WITH A BRAIN INJURY

When we represent people with brain injury it  takes a lot of time, factual inquiry and thought in deciding how to present the damage evidence at trial. The most difficult  question is what to ask a client who is capable of testifying. In general, my belief was that with major injury cases “less was more” because major injuries generally speak for themselves  and don’t need a lot of detail which might make jurors feel you are playing for their sympathy. Once…

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DIRECT EXAM OF TREATING DOCTOR

DIRECT EXAM OF TREATING DOCTOR

We are still in trial so I have limited time to share with you  this week, but here is a simple outline I used during the trial for a treating doctor. I’ve omitted a lot  of references to the hospital records and  exhibits I used  during the examination.  I revised a portion of it to make it appropriate for sharing.  Also, this  is for  a  physician who first  saw the plaintiff in  the hospital. DIRECT EXAM OF  TREATING DOCTOR WHY WITNESS  (Note: The…

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DIRECT EXAMINATION OF ECONOMIST

DIRECT EXAMINATION OF ECONOMIST

I am scheduled to start a trial in a week involving a man who was injured while working. Our economist is scheduled to deliver a baby when the trial is going on  so I  needed to perpetuate her testimony. Here is the simple outline I prepared for her perpetuation deposition. We had discussed this before I used it so she knew the areas I wanted her to cover by these questions. This outline assumes the economist can explain fully the…

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