Although this checklist of issues for treating physicians isn't meant to be comprehensive, it contains some areas of questioning you might want to consider--
- Treatment of plaintiff
- Lay foundation for opinions
- Causation Issues
- Accident/event causing injury
- Ruling out other causes, including those proposed by defense
- Lack of pre-existing problems
- Damage Issues
- Pain suffered by plaintiff, past and future
- Plaintiff's disability, past and future
- Prognosis and need for future medical care
- Foundation for medical bills
- Evidentiary issues
- Demonstrative aids, foundation
- Medical treatises and articles, foundation
If the treating physician is hostile to your position and has given testimony that undermines your case, consider approaching him as you would any opposing expert, by drawing attention to his lack of expertise or the lack of foundation for his opinions. There's a whole range of ideas in this post: "Preparing for Expert Depositions by Looking Ahead to the Cross-Examination at Trial."
For much more about deposing treating physicians, see my book Deposition Checklists and Strategies (James Publishing 2006).
Related post: "Plaintiffs' Lawyers: Meet with the Doctor."