Hi Lee,
Note the inaccuracies in your medical documents and make copies of them before having them correctd by the doctor's offices.
Preparing for deposition~ answer only what you are asked. Do not elaborate. They usually want a yes or no answer and sometimes questions can't be answered quite that easily, however, don't elaborate to the point you're "winging it".
Have your story/facts down pat, and don't stray from those facts. This way when you are asked the same thing a different way or multiple times (which the defense does) you will answer the same way.
The defense is looking for inconsistancies in your version of the accident. Don't give him or her any.
Re implants in your spine that release medication, if you are able to tolerate low dose of oral medication for pain, then there isn't really a reason to go to spine pump yet (if at all), at least I don't think there is. Trying to maintain the most conservative route, as long as it's benefiting you seems to make the most sense.
Good luck with the deposition~
|