I, Jack Shepard, M.D. do hereby attest that I am a physician licensed to practice medicine in the state of Maryland and that I am a board certified orthopedic surgeon. I perform knee surgeries on a routine basis and I am competent to testify in areas of knee surgery and knee replacement surgery.
I further attest that it is my opinion, within a reasonable degree of medical probability, that Dr. John Locke failed to follow the applicable standard of medical care, and that the Dickinson Medical Group, LLC, failed to follow the applicable standard of medical care by and through the act of its agent/employee John Locke, M.D., when John Locke, M.D. operated on James Sawyer’s left knee on December 10, 2012, and that this failure to follow the applicable standard of medical care directly and proximately caused injury to James Sawyer’s left knee, which required Mr. Sawyer to undergo another left knee replacement surgery on October 26, 2013.
I believe this injury is permanent in nature and will prevent Mr. Sawyer from continuing in his chosen employment as a construction supervisor.
I further attest that I do not annually devote more than 20% of my personal activities to activities that directly involve testimony in personal injury claims, that I am not a party to this litigation, I am not an employee or partner of any party to this litigation, that I am not an employee or stockholder of any professional corporation of which any party is a stockholder.
Jack Shepard, M..D.
May 12, 2014
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