Defending my first Medical Expert deposition. I’ve done hundreds of regular depositions, but this is my first expert. Any tips / advise would be really appreciated. Thank you!!

likehelpful
Posting as :
works at
You are currently posting as works at

Work with them beforehand to make sure they know the claims and defenses of your case. Otherwise, if they are indeed an expert, then they should know what to say and what not to say.

like

They generally know what to do, and there's very little to object to

like

If opposing counsel has the same type of expert, make sure your expert has reviewed their report, reliance materials, testimony. If the expert issued a report, make sure they know it. And double check whether there may be additional information that has come out since that may effect their opinions (and go over that information with them).

like

Definitely talk to them beforehand. Never go into a dep blind.

like

1. If you can, do a dry run or at a minimum spend 30 minutes on the phone with the doctor the day before just to get a good preview of what they’re going to say.
2. Watch out for questions that call for the doctor to speculate.

like

Good advice here but, in contrast to interaction with a lay witness, this one is highly trained and knows far more what they are doing than you. Presenting a medical expert ought to be a fairly low-exposure assignment. Most medical experts — by far — are more like wind-up toys than anything: They already know what they are going to say and how.

Not to say that you will not rightly be held accountable for the expert’s testimony. You will. But, you do not want to make the “rookie” mistake of over-preparing the expert. The expert may well not appreciate it much.

YOU need to make sure you are straight about all of the records and stuff the expert has reviewed and that he has them and has reviewed them. YOU need to have a pretty good grasp on what the expert will say. Then ask, even a bit humbly.

Think of yourself more like a movie director with a huge movie star or lion tamer. You need them to get to a certain place, but you need to tiptoe around them a bit to make sure you do not put them off. He/she is a doctor. Very likely they will not appreciate you trodding in artfully on their turf but they will get it (and dig you) if YOU are on top of all of YOUR stuff and humble to them.

helpful

Related Posts

How do you all motivate yourselves to grind through the more boring aspects of our work. I'm so sick of investment management and my productivity is tanking because of it.

like
like

i’m in quite the dilemma - I have a new job that requires me to move to another state and remain virtual. However, I requested an exception to delay the move since I became pregnant and other reasons -i.e-no childcare in the state of moving and spouse can’t relocate with me at the current moment. I sent in a medical letter for my pregnancy care by my high risk specialist and they are reviewing this. I have since miscarried and still grieving. have no idea what to do.

likehelpful

1YOE medical device NPI Lead looking for salary perspective

Mechanical engineering grad, joined a medical device startup that I had done co-ops at. 8mo into full-time, pivoted from engineering into more of an operations role doing new product introduction (NPI), now with 3 direct reports.

The combination of startup+medical device+NPI seems very unique and I'm struggling to find salary comparables. Currently making 75k but it feels very low given my new responsibility and impact. Any advice?

like

Hey everyone! I am trying to find a remote customer service representative job. I am a fast learner and would doubt that I can go into any fields. Is it just me who is having a hard time finding the remote job?
Can someone refer me for a remote position?
I am at a point where I need to leave my toxic work environment asap while my manger is out for 2 weeks and there are only 3 ppl working.
I am also sick of commuting back to Manhattan for work with all the traffics and delays.

like

Can someone clarify on the sick leave policy in ACN UK.

1. Is there an annual limit?
2. Can I charge one-two days leave on illness code?
3. Do they really put you in review for 5+ sick days in rolling 12 months?

like

I'm a HS biology teacher with 2 electives, Forensics and Worldwide Medical trends. I am looking for online lab resources, I use labster, Pearson and a colleague and I have started to record what the students would do. We rotate one does the the lab and the other is the narrator but I would still like more options. What do you use? Thanks and good luck to all in these unprecedented times.

like

What are some of the best paid medical fields that don't require a doctorate? Certifications are absolutely fine. I just can't afford to go into doctorate-level debt

like

Is a pre-employment medical screening normal procedure for Indian pharmaceutical companies?

Might be shifting to a outpatient oncology position from a medical social worker in a hospital setting, any pros/cons major differences?

like

Neither my husband nor I are good with change and when my husband and I went for the ultrasound he nervously asked "she's too sick to eat anything other than her vitamins and water, is it ok for her and the baby to go without?" Our doctor just smiled and replied "don't worry, baby takes" I don't know why but that was so funny to us. It kind of became our mantra as we navigate and move our life around that "baby takes," its made it feel more Us vs Change rather than Me vs Him. Thought I'd share

like

For all the other poor souls stuck in ID - do you have a good system for medical record review? Lately I find myself in circles chasing after my assistant/paralegal to make sure that the records actually come in. Also, it seems I am getting more pushback from carriers when I review the records myself. I am happy to have my paralegal do it, but I find when I review a report, I still have to go back through the records to draft a report/analysis. Does anyone have a good system to make this easier?

like

Dallas! Can’t let NY have another one on us 🫣😂 Would love for us to come up with a day (fri or sat) and time (6:30)for our meetup. Lets figure this out together. Meetup spot is Legacy West (Look at comments) after I tally up, ill pick a date and share event deets.

likeupliftingfunny

Can anyone share the salary structure who works remotely for the US, UK or any other foreign company?

Interested to see whether we get the same tax and other benefits as we do get in local jobs like car allowance, medical insurance, internet allowance etc.

#remotework #remotejobs #salarystructure #taxbenifits

Hello there! I currently work in billing at a medical office. I got my Bachelors in Psychology a few years ago but I couldn’t find a position that seemed like a good option for me that was well paying and fulfilling. I tried working as a tech at an Applied Behavior Analysis clinic but it wasn’t a good fit. I’m hesitant to try case management or social work because I worry I won’t like it but I want to use my degree in Psychology. Does anyone have any ideas for me?

like

Hello !! my PWD is in progress and im due for promotion this year (level IV to Level V) my designation would also change but not responsibilities. Will this affect my PWD or PERM process. I reached out to BAL and they said if role/responsibilities change ill have to start from first. Does change of desination mean change of role ?

like

If someone serves in the army for a couple of months only and is discharged for medical reasons, are they still considered a veteran?

like

Hi Fishes,

This is in regards with my resignation. I have resigned on 22nd March (LWD : 22 June ) on medical grounds. Since then, my hr has asked for my prescriptions and medical certificates to give me an early release.

But yesterday, She is stating that my lwd is revised to 18th April with a clause that since my release is on medical grounds I can't join any other orgs before 22june. If joined, there will be problem in background verification.

Please help me out fishes with your advices

Guidance needed :-

I have 10 YOE in fields like Cust. Service, Business development, Cust. Retention, Insurance reimbursement.

All with foreign Language related processes as I know the language. No knowledge of any tech/IT course.

My mother is very ill and to look after, I need to be at home and I want some good WFH opportunities.

Which field/sector/roles I should look for considering the experience ?

Please Help.

like

Trying to pay it forward 🐠: brilliant rising Senior at my undergraduate alma mater [Washington & Lee] wants to take a detour through consulting before Medical School. I’ve given the real...[Cont.]

More Posts

My wife just found out that her name was printed in reverse order (first name under last name and vice versa) on her EAD card. What is the procedure to get it fixed?

Hey Folks,

Selection time! Need your opinion on choosing a not so under the radar yet classy dress watch.

The watches I'm currently considering are:
(continued)

Germans here? I'm in IT implementation and consulting . Earning 75k Euro in germany, plus company car, plus bonus (around 6k) 4 yoe in IT plus 3 yoe in consulting. I feel underpaid.. How does it compare? Thoughts?

like

Are QSUB tax returns considered combined or consolidated returns? I think neither but have a client asking for clarification. I understand the QSUB activity is treated as belonging to the parent s corporation and all activity is reported in one return. The combination occurs outside the irs eyes and wouldn’t be a consolidation or combined reporting. Thoughts?

like

How is Telco team in Paytm? How is the work, WLB, Management and culture?

like

Hello! I am looking for ways to do random grouping for labs and projects for high school science labs. Does anyone have any ideas?

like

I am interviewing for a recruiting specialist role at a San Francisco tech company with 1 year experience as a recruiting coordinator. What salary range can I expect?

like

Starting a new role (in house) and the firm uses Bullhorn. I’ve only ever used Greenhouse or Salesforce and I’m a little worried because I’ve heard bullhorn is a little clunky

like

Anyone have a referral link for Capital one venture?

Any women in the interested in being a surrogate for compensation ?

likefunny

When you’re frustrated with a product, do you take that frustration out on the product? Would you go the customer support route?

like

Hi all- I’m new to real estate investing. What are some books/ reading materials you would recommend to learn about selecting the right investment property, things to look out for, laws etc.?

like

What’s a polite way to respond when you don’t want to be set up with someone? Annoying aunt is trying to force matchmaking even though I’ve said I’m not interested in dating several times. Per my culture (I’m Asian) I should be seeking a partner and married by now but I don’t want to. I’m pretty happy right now without now.

funny

Has anybody left consulting for a technical account manager (TAM) and if so would you recommend that career switch? Currently have 3 YOE and looking to switch to a tech company

like

My boyfriend and I make 200K combined and live in NJ. We have $1000 in monthly car payments combined. That’s all we owe. Our credit scores are in the 800s. We have 50K to put down on a home. We have done the math and I know we can afford much more but he doesn’t want to buy more than a 400K home. I’m almost positive we can afford 500K and be more than ok. But then he starts to talk about how much kids cost and how we will be house poor and we won’t be able to afford kids. 🤔 Am I insane??

like

Hey Fishes,

My YOE=7 and CTC in my current company is 14LPA. Walmart is offering me SDE3 with 30.75 TDS. Is it good offer? Share your thoughts.

like

Have anybody recently done OINP? Had some questions around what employer documents are needed and what support do we need from employer. This is for foreign worker stream with a job offer. Please dm in case able to help

like

Looking for some support. I’ve been at my job for just over a year & it’s become very clear that there is no growth. I received a raise, taking me from $23/hr to $24.60. I’m the only one that does my job, and it involves planning all the marketing, social media, franchisee development, franchisee training, social initiatives, etc. I want to ask for a raise, but what’s reasonable ? (Toronto, Ont)

like

Hi Folks, For 9+ YOE, .Net Angular (Full Stack), Non IT companies like CNH industrial (Gurugram location ) is good to join, package they are offering more than a current offer I have from Known IT product company!
Pls add if someone know about WLB and Job Security at CNH industrial!

like

Additional Posts in Litigation & Arbitration

I’m a current biglaw associate thinking of lateraling to Quinn Emanuel. Looking for a more dynamic and trial-focused litigation practice, but I’m a little put off by how poorly Quinn seems to invest in support (tech, paralegals, etc) and generally seems to nickel and dime its associates. Curious how these issues feel for Quinn associates on a day to day basis.

like

Anyone familiar with Peckar Abramson in NJ? Saw a lateral opportunity and I'm coming from a small firm. What's the jump like for those who have moved from small into larger groups? Looking for info on billables, pay and WLB. Thanks!

like

Just started at a new firm today. Yearly billables are 1900. Since I started 2 months into the year, do I need to hit the 1900? To recoup the first two months of the year means billing 190 a month.

like

Defendant didn’t show up for his COURT ORDERED deposition (after I moved to compel his depo). Do I need to move to compel again? Or just move for sanctions? Or for default?

like

I have a question about mid-size Philadelphia firms. Does anyone have any insight about what life is like (culture, pay, billable hours, cases, WFH, perks, etc.) as a junior partner/senior associate/of counsel in the litigation department at the following firms: Montgomery McCracken, Schnader Harrison, Stradley Ronon, Dilworth Paxson, Klehr Harrison?

like

Tips on snacks/drinks that keep you going during trial?

like

Anyone have a good website vendor? My firm is looking to change the website design

like

Any insight on Amundsen & Davis? Salary, billable requirement, culture? Specifically looking at the Chicago office.

like

For all the other poor souls stuck in ID - do you have a good system for medical record review? Lately I find myself in circles chasing after my assistant/paralegal to make sure that the records actually come in. Also, it seems I am getting more pushback from carriers when I review the records myself. I am happy to have my paralegal do it, but I find when I review a report, I still have to go back through the records to draft a report/analysis. Does anyone have a good system to make this easier?

like

Best/Coolest/funniest/meanest use of legal analytics- GO!

likefunny

For Houston and Texas specifically, any insight into Vinson & Elkins litigation vs. Kirkland & Ellis litigation?

likefunny

I love a sassy email, especially if I’m only copied because attorney-client privilege attaches 😝

likefunny

Junior litigators, how are you all doing? Am I the only one finding it impossible to manage my own caseload, take on new urgent assignments from partners, and not be burnt out right now? Getting to the point where I’m so behind that I sometimes feel too overwhelmed to even start on my task list. Doesn’t help that partners take forever to review my work so i can get the product to the client. Looking for commiseration & encouragement that things will look up lol!

like

Anyword on whether ny courts will be limiting jury trials? Nj has already issued an order.

like

Is federal magistrate judge a good job? Obviously a pay cut, but what do you think about hours and quality of work? What about exit options? What other pros and cons?

like

Is having too much “attention to detail” a bad thing?

like

I would like to become a mediator in California. I understand you have to do 40 hours training. What are some good companies to use for the training? And is it worth it?

like

In a tiny (only $52,000 in damages) litigation matter that should have been a simple trial on a simple issue (breach of contract), OC has filed 9 unsupportable motions, 7 of which had prayers for fees, including one claiming an ethics violation by me. All overruled. OC's latest brief in opposition to our motion to compel is a 13-page, babbling, word-salad mess with 126 pages of exhibits. It does not address our arguments and any 1L could have written a better brief. Judge should punish her!

likefunny

Does anyone know if in a negligent supervision case against a school district if it’s any kind of mitigating factor that there was not enough money for the school to hire more staff? (Fight broke out between students and there weren’t enough staff to prevent injuries. They would have had more stuff, but there was no budget for it.) Any thoughts? I know the school is held to the reasonable supervision standard. Is it possible they acted reasonably given the constraints of the limited budget?

like

Has anyone had luck finding an epidemiology expert for a covid claim? Defense side. Desperate times, desperate times ... no luck with any major search engines.

like

New to Fishbowl?

Download the Fishbowl app to
unlock all discussions on Fishbowl.
That was just a preview…
Sign Up to see all discussions
  • Discover what it’s like to work at companies from real professionals
  • Get candid advice from people in your field in a safe space
  • Chat and network with other professionals in your field
Sign up in seconds to unlock all discussions on Fishbowl.

Already a user?
Login here

Share

Embed this post

Copy and paste embed code on your site

Preview

Download the
Fishbowl app

See what’s happening in your industry
from the palm of your hand.

A phone with Fishbowl app

Send download link to your phone

OR

Scan your QR code to download
Fishbowl app on your mobile

By continuing you agree to Terms of Use and Privacy Policy.

Messaging rates may apply

Download app

Sign up for free to view this conversation on Fishbowl

By continuing you agree to Terms of Use and Privacy Policy

Already have an account? Log in

Sign up for free to continue using Fishbowl

By continuing you agree to Terms of Use(New) and Privacy Policy(New)
Messaging rates may apply

Already have an account? Log in

For account settings, visit Fishbowl on Desktop Browser or

General

Legal