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Top 100 Questions For Auto Accident Medical Doctor Deposition

Auto accidents are some of the most common types of cases that my firm handles. Most time, a full discovery process is necessary prior to being able to resolve the case. Most good Atlanta lawyers have their own set of questions that they ask the treating doctor in these types of cases. The following questions are the 100 most important general questions. Of course each case is different and there are many more case-specific questions that are covered in addition to these generic questions:


  1. Please introduce your self to the jury.
  2. Dr. ______, where is your practice located.
  3. How long have you been practicing medicine.
  4. What type of medicine do you practice.
  5. Can you explain to the jury what a ________ does.
  6. Tell us about your medical background, starting with medical school.
  7. Are you licensed to practice in Georgia.
  8. Are you Board certified.
  9. What does it mean to be board certified.
  10. What area are you board certified in.
  11. When did you receive your board certification.
  12. Where did you receive your board certification.
  13. Are you currently a member of any medical associations.
  14. Tell us about them.
  15. Do you hold any special positions within any of your associations.
  16. Are you on the staff of any hospitals.
  17. Have you done any writing or lecturing in the area of your specialty.
  18. What have you written.
  19. Where have you lectured.
  20. In your practice, do you treat people with back injuries.
  21. What percentage of your practice would you estimate deals with back injuries.
  22. In your practice, do you treat people who have been injured in automobile accidents.
  23. Have you had occasion to treat people in your practice who have injured their backs in automobile accidents.
  24. Can you estimate how many patients you have treated over the years that have injured their backs in automobile accidents.
  25. Today, I want to ask you about your care and treatment of __________, and, if you will, feel free to refer to your chart, could you tell the jury if you have had occasion to see or treat _______ for your specialty of  _____________.
  26. When did you first see _______ as a patient.
  27. Who referred  him to you.
  28. What was the reason for the referral..
  29. When you first saw __________ did you take a history.
  30. Can you explain to the jury what a history is.
  31. Why is it important to take a history.
  32. What history was obtained from ________.
  33. Who gave you the history.
  34. Did you perform a physical examination of __________ after you obtained the history.
  35. Describe the physical examination.
  36. What were your findings.
  37. Did you conduct any further specialized examinations.
  38. Did you performs any medical testing to __________.
  39. Which tests did you perform.
  40. What were the results of the test.
  41. What was your diagnosis of _________- after the first visit.
  42. Was your diagnosis based upon the history, examinations, and tests you took.
  43. After __________’s first visit, did you form an opinion as to the cause of his back injury.
  44. What conclusion did you reach.
  45. Was your opinion based upon a reasonable medical probability.
  46. What is you understanding of ________’s medical treatment prior to seeing you.
  47. Have you reviewed _________’s medical records for other treatment.
  48. Is there anything in those records which would cause you to change your opinion either then or now.
  49. Did you review the report from the medical exam his employer sent him to on January 29, 1998.
  50. What does the term maximum medical improvement mean.
  51. Did the physician performing the exam on Jan. 29, 1998 reach a conclusion regarding _____’s maximum medical improvement.
  52. What was that conclusion.
  53. When _______ saw you for his first visit, did you feel that he had reached maximum medical improvement.
  54. Do you disagree with the assessment of the physician who performed the exam on Jan. 29, 1998.
  55. Why did you disagree.
  56. What treatment was rendered to ____________.
  57. Did you prescribe any physical therapy.
  58. Did you prescribe any medication.
  59. How many times have you seen ___________ since the first visit.
  60. What were the dates you saw _____________.
  61. How would you describe ___________’s progress during the period of treatment.
  62. When was ___________’s last visit.
  63. What was the purpose for this last visit.
  64. Would you be able to evaluate _________’s current condition if you had not examined him on __________.
  65. Do your notes indicate any significant history between the time you first saw ________ and your last visit.
  66. Is the lack of any significant history during the period of time important to you.
  67. Why.
  68. What were your findings on the last exam of ________.
  69. What was the diagnosis you reached on the last visit.
  70. Is it the same or different from your earlier diagnosis.
  71. Can you explain the term prognosis for the jury.
  72. What is your prognosis for ____________.
  73. Is your prognosis based upon a reasonable medical probability.
  74. Is _________’s injury permanent.
  75. Is your opinion based upon a reasonable medical probability.
  76. Earlier I asked you about the physician who examined _______on _________, and that physician reached a conclusion that _______ had reached maximum medical improvement. Did that physician also assign _______a permanent impairment rating.
  77. What was the impairment rating assigned by the physician that ______’s employer made him go to.
  78. Do you agree with that physician’s assessment.
  79. Why do you disagree.
  80. Can you at this time assign ________ a permanent impairment rating.
  81. What is permanent impairment rating.
  82. What factors are used to assess a permanent impairment rating.
  83. Using these factors, what percentage impairment do you assign to ________.
  84. What does that mean in terms of the functionality of _________’s back.
  85. Are _________’s injuries painful.
  86. In a minute, I’ll ask you to look at a videotape regarding the causes of pain.
  87. What limitations will __________have in the future.
  88. Is your opinion based upon a reasonable medical probability.
  89. What emotional effects would you expect for an injury such as _________’s.
  90. Will treatment be required in the future.
  91. How often do expect that ________will need future treatment.
  92. What type of treatment will be needed.
  93. Do you have an opinion on the projected cost of __________’s future treatment.
  94. Is your opinion based upon a reasonable medical probability.
  95. What medications will _________need in the future.
  96. Why will he need these medications.
  97. Can you estimate the cost of ________’s future medications.
  98. Doctor, was all the treatment rendered by you for _________’s injury necessary.
  99. What were the charges for such treatment.
  100. Are the charges reasonable for doctors in the metro Atlanta area.

As discussed above, these questions are simply the basic questions that must be covered, and the real meat of the matter is handled with case-specific questions that set the stage for introducing evidence at the trial.

For more than 20 years, Attorney Robert J. Fleming has been handling wrongful death cases, automobile accident cases, personal injury cases, dental malpractice and medical malpractice lawsuits for individuals and families who have been injured or died as a result of the negligence of others in and around the Atlanta, Georgia area, including Alpharetta, Austell, Brookhaven, Chamblee, College Park, Duluth, Decatur, Doraville, Hapeville, Johns Creek, Jonesboro, Lawrenceville, Norcross, Peachtree City, Riverdale, Roswell, Sandy Springs, Stone Mountain, and Smyrna. If you have been seriously injured and would like quality legal representation or if you would just like to consult about your potential case, contact Robert J. Fleming directly on (404) 525-5150 or contact us online.

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