Direct Examination Wrongful Death Plaintiff

Lawyer examining witnessThis is a sample direct examination of a wrongful death plaintiff in a medical malpractice case in Baltimore City that resulted in a $10 million verdict in Baltimore City. This client was absolutely amazing on the stand.

Direct of Cythina
Background
  • GIVE US YOUR FULL NAME
  • WHERE DO YOU LIVE
  • WHO DO YOU LIVE THERE WITH
  • WHAT WAS YOUR RELATIONSHIP TO DENNIS ALLEN
  • DO YOU HAVE ANY CHILDREN
  • DO YOU HAVE ANY GRAND CHILDREN
Tell Us About Your Background
  • WHERE DID YOU GO TO HS
  • DID YOU GO ON TO GET ADDITIONAL TRAINING AFTER HS
  • WHEN DID YOU MOVE TO BALTIMORE
  • WHY DID YOU MOVE TO BALTIMORE
  • HOW DID YOU MEET DENNIS
  • TELL US ABOUT DENNIS WHEN YOU FIRST MET HIM
  • WHAT WAS HIS LIFESTYLE WHEN YOU FIRST MET
  • AT SOME POINT DID HE STOP DRINKING
  • WHAT HAPPENED TO MAKE HIM STOP DRINKING
  • WHEN DID THE TWO OF YOU GET MARRIED
  • DID HE ADPOT SHELLY AFTER YOU ALL GOT MARRIED
Talk a Little bit About Dennis' Work History
  • WHAT WAS THE HIGHEST GRADE DENNIS' FINISHED IN SCHOOL
  • AT SOME POINT DID HE GO BACK AND GET HIS GED
  • AFTER HE GOT HIS GED DID HE CONTINUE HIS EDUCATION
  • WHAT WAS DENNIS' FIRST JOB
  • WHERE DID HE WORK AFTER THAT
  • AFTER HE GOT HIS GED UP THROUGH 2012 WAS HE ALWAYS WORKING
Worked Full Time, but Also was Very Involved With Church
  • SINCE 1977 DID DENNIS ACTIVELY PARTICIPATE IN A CHURCH
  • DID HE HOLD ANY POSITIONS AT THE CHURCHS HE ATTENDED
  • HOW DID HE START HIS CHURCH
  • WHERE IS THE CHURCH LOCATED NOW
  • DOES YOUR FAMILY HELP KEEP THE CHURCH GOING
  • WHO IS THE REVEREND AT THAT CHURCH, CHILDREN INVOLVED?
  • HOW MANY MEMBERS DOES THE CHURCH HAVE
  • WHAT WAS HIS GOAL FOR THE CHURCH
  • WHAT DO YOU THINK SET DENNIS APART FROM OTHER REVERENDS
Describe Dennis as a Father
  • WHAT WERE THE VALUES THAT DENNIS TRIED TO PASS ON TO HIS CHILDRED
    • FAITH
    • EDUCATION
    • PARENTS THEMSELVES
  • TELL ME THE STORY OF WHEN YOU TOOK THE FAMILY AND YOUR PARENTS TO PETE'S PIZZA
March of 2013
  • WHEN DENNIS WENT TO UMMS ON MARCH 11, WHAT WAS YOUR UNDERSTANDING OF WHY HE WAS THERE
  • WHAT WAS THE CONDITION THEY WERE TREATING
  • WERE YOU THERE EVERY DAY HE WAS THERE
  • WERE YOU THERE WHEN THE DOCTORS DID THEIR ROUNDS
  • WERE YOU THERE WHEN THE HOSPITAL STAFF DREW BLOOD
  • WHO WAS ASSISTING DENNIS WITH HIS PERSONAL HYGIENE
  • WHO CLEANED OUT HIS BED PAN AFTER A BOWEL MOVEMENT
March 18th 2013

MORNING -

  • BLOOD REFUSAL - MOTION IN LIMINE
  • EARLY MORNING HOURS - DO YOU RECALL SOMEONE COMING IN TO DRAW DENNIS' BLOOD
  • TELL US WHAT HAPPENED
  • DID ANYONE EVER COME BACK TO DRAW HIS BLOOD
  • HOW WAS HE DOING THE MORNING OF MARCH 18TH
  • AT SOME POINT THAT DAY DID SOMETHING UNUSUAL HAPPEN
  • WHO WAS WITH YOU WHEN THE ALARMS WENT OFF
  • HOW DID YOU AND SHELLY REACT
  • HOW DID DENNIS REACT
  • DID THEY EVER GO OFF AGAIN WHILE YOU WERE THERE
  • WHAT HAPPENED NEXT AFTER THE ALARMS WENT OFF
  • DID HE LOOK ANY DIFFERENTLY TO YOU
Administration of Kayexalate
  • AT SOME POINT DO YOU REMEMBER A NURSE BRINING HIM MEDICINE TO DRINK
  • WHY DID YOU THINK IT WAS MEDICINE
  • AT THE TIME HE DRANK THE MEDICINE DID YOU KNOW WHAT IT WAS CALLED
  • AT SOME POINT DID YOU FIND OUT THAT THE MEDICINE WAS KAYEXELATE
  • AT ANY TIME BEFORE HE DRANK THE MEDICINE DID HE COMPLAIN
    • A BURNING IN HIS LOWER ABDOMIN
    • PAIN IN HIS LOWER ABDOMEN
    • DID HE HAVE DIARRHEA
    • DID HE HAVE ANY BLOOD IN HIS STOLL
After He Drank the Kayexelate
  • AFTER HE DRANK THE MEDICINE DID HE
    • A BURNING IN HIS LOWER ABDOMIN
    • PAIN IN HIS LOWER ABDOMEN
    • DID HE HAVE DIARRHEA
    • DID HE HAVE ANY BLOOD IN HIS STOLL
  • TELL THE JURY WHAT YOU REMEMBER ABOUT HIS STOOLS AFTER HE DRANK THE KAYEXELATE
    • 3 STOOLS IN PARTICULAR WITH DENNIS
  • WHAT DID THE HOSPITAL NURSE SAY THEY WOULD DO WITH THAT INFORMATION
The Night He Drank the Kayexelate
  • HOW WAS HE ACTING
  • WAS HE ACTING LIKE HIMSELF
  • WAS HE COMPLAING ABOUT ANYTHING
  • WHAT IF ANYTHING DID THE DOCTORS GIVE HIM FOR PAIN
  • ANY PAIN MEDICAITON
  • TYLENOL, IBPROFUN, ANYTHING?
  • WHAT DID HE SAY TO YOU THAT NIGHT ABOUT HOW HE WAS FEELING
    • DID HE WANT TO STAY IN THE HOSPITAL
    • DID HE SAY WHERE HE WANTED TO GO AND WHY
    • DID HE TELL YOU WHAT HURT
    • DID HE DESCRIBE HOW IT FELT
Morning of the 19th Conversation About the Kayexlate & Surgery
  • WHEN DR. STEVENS DID HIS ROUNDS, WHAT DID HE TELL YOU
  • WHAT WAS GOING THROUGH MIND WHEN HE IS TELLING YOU THIS
  • HOW DID YOU FELL ABOUT WHAT HEW AS TELLING YOU
  • WHO ELSE WAS THERE IN THE ER THAT AM
  • WHAT DID YOU SAY TO HIM AFTER HE TOLD YOU THAT
  • WHERE DID HE GO AFTER TALKING TO YOU
  • DID HE EVER SAY ANYTHING ABOUT HIS BOWEL BEING INJURED FROM LOW BLOOD PREASSURE
  • DID HE SAY HOW LONG THE SURGERY WOULD LAST
  • WHO WAS THERE AT THE HOSPITAL DURING THE SURGERY
  • WHAT HAPPENED NEXT
March 20th 2013
  • DID DR. STEVENS COME SEE YOU AFTER THE SURGERY
  • DID DR. STEVENS COME SEE YOU AFTER YOUR HUSBAND PASSED AWAY
What Do You Miss The Most About Dennis More Help for Plaintiffs' Lawyers
  • Baltimore Sun article on this verdict
  • Sample Trial Materials: get more example direct and cross-examination of witnesses, sample opening and closing statements and really everything you need to know to get a medical malpractice or auto tortready for trial
  • Attorney Help Center: depositions, interrogatories, and other discovery to help put the case in position to win at trial

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