Plaintiff Attorney Legal Information CenterIf you’re preparing for a wrongful death deposition involving a medical expert witness, this sample outline offers a detailed framework tailored for cases involving burn injuries, chemical exposure, and hospital negligence.
Offered for plaintiffs’ attorneys handling burn injury or other wrongful death lawsuits, this deposition template covers expert qualifications, causation testimony, pain and suffering, and cause of death—all within a medically complex context. Whether you’re seeking a sample deposition of a doctor in a wrongful death case or need guidance on expert testimony in burn injury litigation, this outline provides a practical, courtroom-ready format you can adapt to your case.
Deposition Outline: Medical Expert Witness
Deposition Date: April 11, 2025
Patient: Sarah Martin
Incident Date: July 28, 2024
Facility: Bayview Medical Center
I. QUALIFICATIONS & EXPERT DESIGNATION
Background and Credentials
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Please state your full name and business address for the record.
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Could you summarize your educational background?
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Where did you attend medical school?
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In what year did you graduate?
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Where did you complete your medical residency?
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What field was your residency in?
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Where were you employed following your residency?
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How long have you been in private practice?
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What is the nature of your private medical practice today?
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Are you affiliated with any hospitals? If so, which ones?
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Are you board-certified? If yes, in what specialty?
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Are all medical doctors required to be board-certified?
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Have you ever served in a teaching or academic role in your field?
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Have you authored any publications, journal articles, or presented at medical conferences?
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Have you previously been qualified as an expert in court proceedings? Approximately how many times?
Expert Designation
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Your Honor, we offer Dr. Henry as an expert in the fields of internal medicine, trauma care, and the treatment of complex burn injuries.
II. GENERAL MEDICAL OPINIONS ON BURN INJURIES
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Could you explain the difference between first-degree, second-degree, and third-degree burns?
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How are each of those types typically treated?
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What factors determine the severity of a burn injury?
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Are chemical burns different from thermal or electrical burns in terms of tissue damage and medical response?
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How do underlying conditions (e.g., diabetes, respiratory issues) affect a patient’s recovery from serious burns?
III. RECORD REVIEW
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Did you review any medical records or other materials in preparation for your testimony today?
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What specific records did you review?
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Did you rely on those records in forming your opinions?
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Did you consult any additional literature or medical guidelines?
IV. MEDICAL RECORD FUNDAMENTALS
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What is meant by a “medical history”?
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Why is a patient’s medical history significant in evaluating trauma and treatment options?
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What is the importance of pain documentation in assessing patient condition?
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What is the standard of care for chemical burn exposure in a hospital setting?
V. CLINICAL TIMELINE: PATSY MARTIN
Day One – Friday, July 28, 2024
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What was the history taken from Patsy Martin upon her arrival at Bayview Medical Center?
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What were her initial complaints and symptoms?
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What was her admitting diagnosis?
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What is your understanding of the chemical composition of the substance she was exposed to?
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Two diagrams show the location and extent of her burns—what do they tell you about her injuries?
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What was her level of consciousness upon arrival?
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Is there any indication that she lost consciousness at any point?
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Can you explain the Glasgow Coma Scale and her recorded score?
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What was her initial pain rating?
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How soon after admission did she receive pain medication or sedatives?
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Did the facility face any delays in identifying the chemical agents involved in the burn?
Day Two and Three – July 29 & July 30, 2024 (Saturday & Sunday)
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How would you characterize her condition during the second and third days?
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What was her heart rate and respiratory status during this period?
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Was she receiving IV fluids, antibiotics, or wound care?
Day Four – Monday, July 31, 2024
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Did she begin to experience respiratory distress?
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Was she placed on a non-rebreather face mask?
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What is a non-rebreather mask, and why is it used in cases like this?
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Were additional labs ordered at this point, such as arterial blood gases?
Day Five – Tuesday, August 1, 2024
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What surgical intervention was performed on this date?
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Please describe the nature and extent of that procedure.
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How did she respond immediately following surgery?
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Were her burns consistent with what the surgical team expected?
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Was an endotracheal (ET) tube placed postoperatively?
Day Six – Wednesday, August 2, 2024
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The records indicate she developed respiratory acidosis. Can you explain what that is and its significance?
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She became hypotensive. What does that mean, and what are the implications?
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What is a Swan-Ganz catheter, and why was it placed in this patient?
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What is a femoral arterial line? How does it assist in patient management?
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The notes mention Systemic Inflammatory Response Syndrome (SIRS). What is that, and how does it relate to severe burn cases?
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What is sepsis, and how does it develop in burn patients?
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The records mention hypoxia. What is hypoxia, and why does it occur in cases like this?
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What are the risks of multi-organ failure following severe burn trauma?
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On what date and time did Patsy Martin pass away?
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What was the listed cause of death, and do you concur with it?
VI. OPINIONS – CAUSATION & DAMAGES
Causation of Injury
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Do you have an opinion, within a reasonable degree of medical certainty, regarding what injuries Patsy Martin sustained as a result of her exposure to a hot liquid containing chemicals?
What is that opinion?
Pain and Suffering
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Do you have an opinion as to whether the pain and suffering she experienced were caused by that chemical exposure?
What is that opinion?
Causation of Death
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Do you have an opinion, within a reasonable degree of medical certainty, as to whether her death was caused by her exposure to the chemical liquid?
What is that opinion?
Billing and Medical Necessity
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Are you familiar with the charges billed by Bayview Medical Center in this case?
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In your opinion, were those charges fair, reasonable, medically necessary, and causally related to her injuries?
Please explain your reasoning.
VII. CLOSING & FOLLOW-UP
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Based on the course of treatment, what could have improved her prognosis, if anything?
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Was there any deviation from the standard of care in the treatment she received?
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Is there anything else in the records or clinical timeline that stands out to you as significant in understanding how and why Patsy Martin died?
More Samples for Trial Lawyers
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