Deposition Questions to Medical Records Custodian

Written questions deposition of a medical records custodian

Obtain medical records, plus the foundation to put those records into evidence --- even if the medical records are stored electronically.

Written depositions of medical records custodians depositions are an efficient way of obtaining medical records, plus the authenticating testimony to put those records into evidence. To do that, you must draft the right written questions. Use a form to be sure you include the questions needed to establish needed elements of authenticity and foundation. Put drafting your questions on auto-pilot.

Written Deposition Questions to Medical Records Custodian gives you:

  • 15 Vital Questions. You get the 15 vital, and crafted, questions you should ask - every time - if you want to put medical records into evidence via deposition testimony. It not only is useful for written depositions, the questions in this form also are your checklist on the oral deposition of any medical witness "live", such as the treating doctor, when he/she has medical records you want to put into evidence!
  • Time. A good legal form saves you time. Don't reinvent the wheel, and don't waste time when you have more important things to do.
  • A "Best Practice": You can delegate the "draft the written questions to the medical records custodian" part of your bodily injury practice. Forms allow you to efficiently delegate to your secretary or legal assistant the job of preparing the questions you need to serve for a deposition on written interrogatories of the medical records custodian.

Use a form to auto-pilot the process of drafting written questions that invite the answers you need from medical records custodians. Of course, as a lawyer, you must determine for yourself our form's fitness for your purpose, and apply your professional legal skills to determine the legal requirements of your local jurisdiction. But 99% of the time, these questions are all you need to submit to get what you want.

Trial lawyers in the author's law firm used Plaintiff's Request to Medical Providers for years in a busy trial practice. The author refined this SOP form over the years to maximize getting rote "yes" responses from the medical provider or custodian on the witness stand.

Rule 31 of the Federal Rules of Civil Procedure, and like state court rules, provide:

"Rule 31. Depositions by Written Questions. (a) When a Deposition May Be Taken. (1). Without Leave. A party may, by written questions, depose any person ....(2). The deponent's attendance may be compelled by subpoena under Rule 45.....(3) Service; Required Notice. A party who wants to depose a person by written questions must serve them on every other party, with a notice stating ...."

Plaintiff's Request to Medical Providers is designed to be used with the federal Rule 31, and has been used in many states with similar state rules of civil procedure. A deposition by written questions is an efficient way to procure medical records and the testimony to authenticate them to be used as evidence.

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