If there is a
deposition on written questions to obtain medical records -- plaintiff also
should use the questions which will get the medical bills and
foundation for trial evidence. Use the
Questions to Medical Bills Custodian legal form.
Plaintiff's Questions to Medical Bills Custodian
get 15 vital questions you should ask - every time - if you want to put
medical records into evidence via deposition testimony. It not only
is useful for written depositions, the questions in this form also are
your checklist on the oral deposition of any medical witness "live", such
as the treating doctor, when he/she has medical records you want to put
A good legal
form saves you time. Don't reinvent the wheel, and don't waste time when
you have more important things to do.
A "Best Practice".
You can delegate the "draft the written questions to
the medical records custodian"
part of your bodily injury practice. Forms allow you to
efficiently delegate to your secretary or legal assistant the job of
preparing the questions you need to serve for a deposition on written
interrogatories of the medical records custodian.
Two ways for plaintiff to use Plaintiff's Questions to
Medical Bills Custodian:
- Defense noticing deposition. When the defense
notices the deposition on written questions of a medical
records custodian - you as the plaintiff has an inexpensive
option to serve cross-questions. It doesn't cost more
than the expense of typing the cross-questions. And, if you are
using a form like Plaintiff's
Questions to Medical Bills Custodian, then the cost
is really minimal.
The civil rules option to respond with additional written questions
is the way to get not only the bills, but also - usually in
actual practice settings - sufficient authenticating and opinion evidence of the amount and reasonableness of the
medical expense to put the bills into evidence for the plaintiff.
(Defense counsel usually do not notice what is happening with the
cross-questions, and if they do, they normally do not know exactly
how to respond.) Plaintiff's
Questions to Medical Bills Custodian is most often
by the plaintiff when a defendant notices a deposition on written
questions to ask for medical records. Hence, it is written the format for
written cross-questions. Cross-questions are submitted under the
procedure outlined in Federal R. Civ. P., Rule 31, or similar state
- Plaintiff noticing deposition. You as a plaintiff's
bodily injury attorney sometimes may notice the deposition of a medical records custodian on
written questions, to obtain the medical records of the plaintiff,
with a business records foundation.
The additional questions in Plaintiff's
Questions to Medical Bills Custodian regarding the medical bills can be added to the
plaintiff's set of direct questions
regarding the medical records. If you are using these questions as a part of plaintiff's own
deposition on written interrogatories of a medical record librarian or
custodian, simply add these medical bill questions from this form to
the end of your written questions regarding the medical records.
Although the testimony on medical expenses may not
always be sufficient to provide a foundation for the opinions on
reasonableness of the medical expenses, it is always worth-while (the
cost to benefit ratio is high) for a
plaintiff to ask Plaintiff's Questions to
Medical Bills Custodian. Why?
- It costs plaintiff no more than his/her legal
assistant preparing the questions using the following form. (And in
the case of the defendant noticing the deposition, the defendant is
paying for the deposition. So why not try to get something for
- The medical custodian usually gives appropriate
affirmative answers to the opinion questions as a
matter of rote C they are
so used to saying "yes" to every question the court reporter
reads to them. But the
defense attorney usually is not alert enough to serve either
written objections (or know how to draft appropriate re-direct written questions to
establish that the medical custodian really knows nothing first
hand regarding why the expenses were needed, or what the reasonable
charge is in the locality.) In most jurisdictions, if the defense
attorney does not object to form or foundation before the written
deposition, the objections to
qualifications and foundation for the opinions are waived.
- Plaintiff's Questions to
Medical Bills Custodian only costs $12.90. That's a
small investment that is repaid every time you use this form
and save ten minutes.
Note: our #MED4707 is the form for medical reports and records,
as opposed to the legal form described on this page (#MED4708, which targets the medical bills). So, see
Written Deposition Questions to Medical Records Custodian if it you
want medical records, plus the foundation to put those records into evidence ---
even if the medical records are stored electronically.
list of available litigation forms
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