There are certain items you always will want to see when you take the deposition of an adverse medical doctor. Preferably you have obtained them before the deposition by a request to the adverse party. Nonetheless, use a subpoena when you take the deposition of the adverse doctor, and always ask for all the items in our form Duces Tecum Demand to Doctor being Deposed.
Not only does this form have a three page form your secretary or legal assistant can routinely just copy and put into the subpoena for your signature, the form also includes a four page report with mentoring advice. For example, if you do not know the three main reasons for using the duces tecum subpoena to the doctor, even if you have previously served the adverse party with a notice to produce the same items, this four page report will give you the advice you should have.
Our Duces Tecum Demand to Doctor being Deposed Checklist is a versatile form. You will use it to:
- Get the documents you want to see.
- Suggest examination questions you want to ask the doctor or hospital employee.
- Be your checklist of records during the deposition.
- Prepare your own doctor for the subpoena she may get from the adverse attorney the day before they take her deposition.
You know that in today’s hospitals and medical practices, often records are maintained only in electronic instead of paper format. Our included report tells you why you should prefer getting the electronic record rather than a paper printout. This form — Duces Tecum Demand to Doctor being Deposed — shows you how to ask for both electronic format and paper printout with a fall back demand if the person subpoenaed demands their right under the new federal rules to produce the records in one format only.
We are selling the Duces Tecum Demand to Doctor being Deposed for only $18. If this form saves you just 15 minutes it will have paid for itself!
All The Best,
Leonard Bucklin, Civil Trial Attorney
P.S. This Duces Tecum Demand to Doctor being Deposed is not a checklist or forms for issuance of the subpoena. This Duces Tecum Demand to Doctor being Deposed tells you what to have in the duces tecum list, and suggests questions to ask. If you are looking for the HIPAA requirements and HIPAA compliant process for issuance of a subpoena, see our Form #BI4613 HIPAA Compliant Subpoenas.
