If you are taking the testimony of a plastic surgeon at a deposition or trial --- you need the vital tips and checklist outline of questions of this form.
Seven single spaced pages of tips and additional questions to ask in a deposition or trial, if the medical witness is a plastic surgeon.
A plastic surgeon (a.k.a. reconstructive surgeon) often can be a useful additional medical witness. On the plaintiff's side, a plastic surgeon will focus the jury or judge on the issue of mental suffering from disfiguration. Importantly for a plaintiff's presentation, plastic surgeons normally take an excellent set of "before and after" pictures for their file on the patient. If you introduce the surgeon's pictures as glossy 8 x 10's, the photo of a scar becomes a strong argument in the jury room.
Further, if you want the jury to award the money for future reconstructive surgery, you need this specialty on your side. Usually the only medical witness who has the expert credentials to state the "reasonable value of future medical expense for reconstructive surgery" is a plastic surgeon. Without that testimony, you are left with no testimony to support an award for future reconstructive surgery.
When you represent the injured person, it is important that you as a lawyer ask the questions that will allow the plastic surgeon to testify to important facts of reconstructive surgery. You need to be aware of tips that we give you in our form #MED3432 Plastic Surgeon Testimony, such as the following.
When you represent the defendant, a plastic surgeon may be able to help you with testimony that the plaintiff's disfiguring scar seen in the courtroom is not permanent ("unless the plaintiff wants to keep it permanently"), because it may be removed by reconstructive surgery which will render the scar "inconspicuous".
#MED3432 Plastic Surgeon Testimony will be of high value to you, giving you the tips that prevent errors of omission or commission in the questions you ask a plastic surgeon in his/her deposition or trial (direct or cross-examination).
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