In a past post, I wrote about questions you should ask in every deposition. Here are a few more key questions when the deponent is a defendant doctor in a medical malpractice case:
- Whether the doctor has ever had a medical license suspended or revoked;
- The contents of the doctor's medical records, if handwritten and hard to read;
- Whether the doctor's preparation for the deposition included the review of any medical literature, and if so, what it was;
- Whether the doctor, in his view, committed any errors of judgment in their treatment of the patient;
- Conversations about the event with the patient, family members or other doctors;
- The doctor's understanding of medical definitions important to the case, and whether these definitions are commonly accepted in the medical community.
Source: "15 Key Deposition Techniques in a Medical Malpractice Case," by Gerry Oginski writing at the South Carolina Trial Law Blog.