Direct-Examination of Dr. Johnson (Treating Doctor)

• BRIEF BACKGROUND OF YOUR EDUCATIONAL EXPERIENCE
• BRIEF BACKGROUND OF YOUR WORK EXPERIENCE

• WHAT RECORDS DID YOU REVIEW IN THIS CASE
• DID YOU CONDUCT A PHYSICAL EXAM OF MR. VANDERBILT
• DID YOU TALK TO STEVE ABOUT HIS JOB
• ARE YOU AWARE OF WHAT HE DOES FOR A LIVING
• ARE YOU AWARE OF THE PHYSICAL DEMANDS THAT ARE PLACED ON HIS BECAUSE OF HIS JOB

• HOW DID STEVE PRESENT IN THE EMERGENCY ROOM
• WHAT DID THE DOCTORS DO FOR HIM IN THE ER
• WHAT TYPE OF PAIN MEDS WAS HE ON IN THE ER
• WHAT DID THE X-RAYS REVEAL
• WHAT WAS HIS DIAGNOSIS
• WHAT WERE HIS D/C INSTRUCTIONS
• DID NEED ANY TYPE OF DEVICE TO ASSIST HIM WITH WEIGHT BEARING
• WAS HE DIAGNOSED WITH THE ACL TEAR AT THIS POINT

• WHAT WERE THE OBJECTIVE FINDINGS
• WHAT WERE DR. HERRON’S DIAGNOSIS
• WHAT IS COMPARTMENT SYNDROME
• WHAT WERE HIS RECOMMENDATIONS
• WHY WAS IT IMPORTANT AT THAT TIME TO MAINTAIN MOTION IN FEET AND ANKLES

DIRECTING YOUR ATTENTION TO THE NOTE OF 4/2/11, HOW DID KEVIN PRESENT IN HIS HEALTH CARE PROVIDERS? (Knee is the size of Bolivia)

• WHAT IS SEPTIC ARTHRITIS?
• WHAT TYPE OF SURGERY DID HE HAVE IN APRIL?
• DESCRIBE THE SURGERY
• HOW WAS HE DOING IMMEDIATELY AFTER THE SURGERY?
• 6 WEEKS AFTER THE SURGERY ON 5/14/11 -HOW WAS HE DOING?
• WHAT WERE THE DRS RECOMMENDATIONS?

• ON 6/4/11 WHAT WERE THE DRS RECOMMENDATIONS?
• DESCRIBE THAT PROCEDURE FOR US?
• DONE UNDER GENERAL OR LOCAL ANESTHESIA?
• WHAT IS A PAIN PUMP?
• WHAT IS THE PURPOSE OF A PAIN PUMP?
• AT SOME POINT DID RYAN HAVE A PROBLEM WITH HIS PUMP?
• AFTER TWO SURGERIES ON 6/18/11-HOW IS HE DOING?

• IN JULY RYAN WENT TO JHH AND SAW DR. SILBERSTEIN, WHAT WERE DR SILBERSTIEN’S FINDINGS?
• HOW WAS HE GETTING AROUND AT THAT TIME? (Limping and left foot turned out)
• WHAT WAS THE DRS DIAGNOSIS?
• WHAT WAS THE DRS RECOMMENDATIONS?
• DID DR. SILBERSTEIN REFER HIM TO ANY OTHER DR?
• WHAT WERE DR. COSGERA’S FINDINGS?
• DID HE HAVE ANY OTHER TYPE OF DIAGNOSTIC TESTS?
• WHAT DID HIS MRI REVEAL?
• DID HE HAVE A NERVE CONDUCTION STUDY TE?
• WHAT DID THAT REVEAL?

• FIRST PT EVALUATION WITH HS, WHAT WERE HIS COMPLAINTS?
• HOW LONG WAS HIS THERAPY? (4/9/11-12/5/11) 8 MONTHS
• WHAT DID HIS THERAPY INVOLVE?
• HOW MANY VISITS DID HE HAVE? 90 VISITS
• IS THERE ANY INDICATION IN THE RECORD WHETHER HE NEEDED TO TAKE RX OR NOT TO TOLERATE PT?
• WHAT WERE HIS COMPLAINTS AT THE END OF HIS PT?
• WHAT IS A DYNASPLINT, HOW LONG WAS HE IN THE SPLINT? (7 MONTHS)
• EXHIBIT #1, MEDICAL BILLS $75,418.83, ARE ALL OF THOSE BILLS FAIR, REASONABLE, NECESSARY AND CAUSALLY RELATED TO THE ACCIDENT OF MARCH 10, 2111?

• DO YOU KNOW WHEN MR. VANDERBILT WAS RELEASED BACK TO WORK?
• IN YOUR OPINION WAS HIS TIME OFF FROM WORK REASONABLE AND RELATED TO THE ACCIDENT?

• WHEN DID YOU FIRST MEET RON VANDERBILT?
• DID YOU TAKE A HISTORY FROM HIM?
• WHAT WAS YOUR UNDERSTANDING OF HIS JOB REQUIREMENTS?
• DID YOU CONDUCT A PHYSICAL EXAM?
• WHAT DID YOUR PHYSICAL EXAM REVEAL?
• WHICH OF THOSE FINDINGS ARE OBJECTIVE INJURIES?
• BOIL DOWN WHAT HIS INJURIES WERE AND WHAT HIS CURRENT CONDITION IS?
• IS THIS CONDITION GOING TO GET BETTER OR WORSE OVER TIM?
• WOULD THE TYPE OF INJURIES THAT RYAN SUFFERED CAUSE A PERSON PAIN?
• DESCRIBE FOR JUDGE JONES THE LIMITATIONS THAT STEVE HAS NOW WITH RESPECT TO HIS ABILITY TO LIFT HEAVY OBJECTS?
• DESCRIBE FOR JUDGE CASULA THE LIMITATIONS THAT STEVE HAS NOW WITH RESPECT TO HIS ABILITY TO KNEEL?
• DO HIS INJURIES AFFECT HIS ABILITY TO SQUAT AND BEND AT THE KNEES?
• DO HIS INJURIES AFFECT HIS GENERAL ENDURANCE?

HAVE ALL OF YOUR OPINIONS BEEN WITHIN A REASONABLE DEGREE OF MEDICAL CERTAINTY?

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