Pennsylvania Sample Medmal Interrogatories
Every malpractice action is different and your interrogatories should be tailored accordingly. A couple other issues to consider, however, that fall outside of these interrogatories are:
1. Request for the continuing education records of the doctors in question.
2. An inventory of the defendant doctor's billing codes like the ones at issue in your case.
3. The electronic version of your client's complete medical records.
4. Imaging studies and the complete radiological file.
5. Hospital's policies and procedures for how medical documents are to be preserved/stored.
6. An index of all the hospital's polices and procedures- allows you to pick what you want.
7. Employment agreements between the doctor and his practice or hospital.
8. Contracts between a group practice and the hospital.
9. Doctor's schedules at the critical case times.
10. Audio recordings of pages and telephone calls among your client's doctors at time in question.
11. Surveillance videos.
I have to credit these eleven additional ideas to attorneys Patrick Malone and Rick Friedman from their amazing book "Winning Medical Malpractice Cases with the Rules of the Road". You can buy that book here on the Trial Guides website.
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