Workers’ Compensation

Ca. Workers' Comp. Quarterly 2018, Vol. 31, No. 3

The Case for Leaving Loose Ends—An Introduction to Strategy for Deposing Doctors


Los Angeles, California

My niche for the better part of the last decade has been deposing medical experts for other attorneys in the areas of workers’ compensation and personal injury law. One question I occasionally get from my clients is, "Why didn’t you nail it down?" What the client means is that they wanted particular testimony, and they wanted it crystal-clear, and they weren’t happy that this didn’t happen. What I must explain to them is that I made a deliberate decision not to nail it down but instead to leave loose ends. This article explains the decision-making process and strategy for leaving those loose ends in the deposition of a doctor.

Lay the Foundational Facts

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