Expert Deposition Notice

JOHN Q. PUBLIC
Plaintiff,

v.

ANY HOSPITAL USA
Defendant.

************

IN THE CIRCUIT COURT FOR BALTIMORE CITY
CASE NO. 00-C-00-000000 MM

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NOTICE OF VIDEOTAPED DEPOSITION OF DON DONALDSON, M.D.

You are hereby notified that Plaintiff, John Q. Public, by and through his attorneys, Rodney M. Gaston and Miller & Zois, LLC, pursuant to the Maryland Rules of Civil Procedure, will take the deposition upon oral examination of the below named person on the date and time and at the location indicated below before a person duly authorized to administer an oath under Maryland law. The deposition will be recorded via stenographic, audio, and/or videotaped means for the purpose of discovery and/or used as evidence and/or any other purposes permitted by the Maryland Rules of Civil Procedure, including use at trial, and will continue day to day until completed. The Deponent shall bring to the deposition the documents /things listed on "Schedule A" attached hereto.

DEPONENT: DON DONALDSON, M.D.
DATE: Wednesday, June 1, 2016
TIME: 2:00 p.m.
LOCATION: Miller & Zois, LLC
1 South Street, Suite 2450
Baltimore, Maryland 21202

"SCHEDULE A"

  1. Deponent's complete file concerning this matter, including, but not limited to, any and all medical records, office records, notes, correspondences, emails, memoranda, bills, diagrams, documents, test results, and reports relating to the care and treatment of John Q. Public.
  2. Any and all documents, deposition testimony, photos, radiographic materials/films videotapes, and slides which the Deponent has reviewed for this case.
  3. Any and all documents which the Deponent has reviewed in preparation for the deposition.
  4. Any and all documents, including medical texts, treatises, or articles reviewed by the Deponent which relate in any way to the medical issues in this case from the date he/she was first contacted by any attorney to act as an expert witness in this case.
  5. Any and all medical texts, treatises, articles, reports, experimental data, or other data relied upon by the Deponent, or any experts, to support his opinion(s) in this case and/or which the Deponent finds to be reasonably reliable for the medical issues involved in this case.
  6. Expert Deposition Notice
  7. A recent copy of Deponent's Curriculum Vitae.
  8. Copies of any and all demonstrative evidence and exhibits pertaining to the issues in this case and those which are relied upon by the Deponent and which may relied upon by the Deponent for any opinion the Deponent expects to provide in this case.
  9. Any and all correspondence, in any format, to and from Deponent and all Defendants and any expert witnesses.
  10. Copies of any agreements and/or contracts by and between the Deponent and all other Defendants in this case and the attorney who retained the deponent.
  11. A list of cases wherein the Deponent provided deposition testimony or trial testimony in the last four years.
  12. Copies of any and all emails and all other correspondence by and between the Deponent and the Defense attorneys and other parties in this case.
  13. A copy of all reports the Deponent authored in this case to include any and all drafts.
  14. Copies of any and documents, including your own bills and invoices, which reflect any payment for medical legal services in this case.
  15. Copies of any and all notes you created pertaining to this case whether they were created in paper format or on a computer or other electronic device.
  16. Copies of the pages of any of the Plaintiff's expert witnesses' deposition testimony which contain statements and or opinions which you disagree with.
  17. Copies of any medical articles and any other publication which were authored or cop-authored by the Deponent which relate to the medical issues involved in this case.
  18. A copy of your bill for expert witness services you have provided to date in this case.
  19. A copy of any guidelines and/or rules and/or protocols which are published by any medical professional organization which you believe are reasonable for physicians such as the Defendants in this case to have followed for the medical treatment of John Q. Public.
  20. A list of and a copy of every medical article, publication, medical study, which you have read which you claim are supportive of the opinions which you intend to give in this case and supportive of the actions taken by the Defendant.
  21. Copies of any and all depositions which you have given in medical malpractice cases in the last five years.

IF ANY OF THE ABOVE REQUESTED MATERIALS ARE ON A DATA DISC, THE DEPONENT IS REQUESTED TO BRING COPIES OF THE DATA DISC WITH HIM/HER TO THE DEPOSITION.

Respectfully submitted,
MILLER & ZOIS, LLC

____________________________

Rodney M. Gaston, Esq.
1 South Street, Suite 2450
Baltimore, Maryland 21202
T: (410) 553-6000
F: (844) 712-5151
Attorneys for the Plaintiff

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