Interrogatories for Use by Either Party

1. If you intend to rely upon or use in direct examination any medical article, treatise, or other publication, identify the document and state:

(a) the title of the publication, journal, magazine, or treatise in which each document was published,

(b) the name and address of the publisher,

(c) the date of publication, and

(d) the volume and page or section referenced.

(Standard Medical Malpractice Interrogatory No. 1.)

Interrogatories to Defendant from Plaintiff

31. Describe the nature and duration of the professional or business relationship between you and any other Defendant.

(Standard Medical Malpractice Interrogatory No. 31.)

32. State your professional medical training, qualifications and experience, including:

(a) each university or college you attended, each degree awarded to you, and the date of each award;

(b) each hospital with which you have been affiliated at any time up to the present, and the nature and inclusive dates of each affiliation.

(c) each medical society or association of which you have ever been a member, and the inclusive dates of your membership;

(d) each specialty or subspecialty for which you have been certified by an American speciality or subspecialty board, and the date of each certification; and

(e) a bibliography of all your publications, including titles, dates and publishers.

(Standard Medical Malpractice Interrogatory No. 32.)

33. List, by date and time of day, each occasion on which you saw the Patient, and as to each occasion, describe in detail:

(a) the nature and scope of your examination of the Patient;

(b) the nature and scope of any conversation you had with the Patient or with anyone who accompanied the Patient;

(c) what you observed or were told about the Patient’s condition; and

(d) the treatment you provided or ordered to be provided for the Patient.

(Standard Medical Malpractice Interrogatory No. 33.)

34. Describe in detail and chronological order each test, procedure, or other treatment performed or ordered as part of your care of the Patient, and for each:

(a) identify all persons present during the test, procedure, or treatment and state the person’s professional relationship to you, if any; and

(b) state the reasons for, and result of, the test, procedure, or treatment.

(Standard Medical Malpractice Interrogatory No. 34.)

35. For each conversation you had with any other physician or medical professional relating in any way to the care and treatment of the Patient, state the substance, date, time, and place of the conversation, and identify all persons involved.

(Standard Medical Malpractice Interrogatory No. 35.)

36. Identify, in chronological order, each writing or dictation known to you and prepared by anyone concerning the treatment of the Patient and made since you first undertook care of the Patient, and set forth as to each:

(a) the date on which the writing or dictation was made;

(b) the identity of the person who made it;

(c) the meanings, in both lay and medical terms, of all abbreviations and symbols used in it; and

(d) attach a copy or transcription of it to your answers to these interrogatories.

(Standard Medical Malpractice Interrogatory No. 36.)

37. Summarize in detail each conversation that you had with the Patient or with any Plaintiff about any aspect of the Patient’s diagnosis, treatment, care or medical condition, and state the date and place of each such conversation.

(Standard Medical Malpractice Interrogatory No. 37.)

38. If you gave any advice, instruction, or warning that the Patient did not follow, state:

(a) the advice, instruction, or warning that was given;

(b) the identity of all persons to whom you gave the advice, instruction, or warning;

(c) when and where the advice, instruction, or warning was given; and

(d) all reasons given, if any, for not following the advice, instruction or warning.

(Standard Medical Malpractice Interrogatory No. 38.)

39. If you contend that, by any act or omission occurring at any time during or following the Patient’s care and treatment, the Patient caused or contributed to the Patient’s injury or death, state the facts that support your contention.

(Standard Medical Malpractice Interrogatory No. 39.)

40. State your contention as to each cause of the Patient’s death or injury that is alleged in the complaint and, as to each cause:

(a) state the facts upon which you rely;

(b) identify each document containing information that supports your contention;

(c) Identify each person who you contend is responsible, in whole or in part, for the Patient’s death or injury that is alleged in the complaint and your reasons for contending that the person is responsible; and

(d) state the professional relationship to you, if any, of each person named in your response to this Interrogatory.

(Standard Medical Malpractice Interrogatory No. 40.)

41. List by author, title, publisher or publication, any texts, treaties, articles or other works which, at the time the Patient was under your care, you regarded as reliable authority with respect to the care that you rendered to the Patient.

(Standard Medical Malpractice Interrogatory No. 41.)

42. Identify each instance in which you have been named a defendant, or have testified as an expert witness, in any other claim or suit for personal injury, negligence, or medical malpractice, including in your answer to this Interrogatory:

(a) the identity of the person or organization who brought each claim or suit;

(b) the date of the filing of each claim or suit;

(c) the identifying number of each claim or suit;

(d) the date, place, and nature of the occurrence from which the claim or suit arose; and

(e) the final disposition of each claim or suit.

(Standard Medical Malpractice Interrogatory No. 42.)

43. Identify each person that undertook an investigation of the events surrounding the Patient’s death, and for each also state:

(a) the person’s title or position;

(b) the date(s) upon which the person conducted the investigation;

(c) the identity of each person contacted or to whom the investigator spoke regarding the events giving rise to this action;

(d) any remedial or corrective action taken as a result of the investigation; and

(e) whether there is a written report or other document containing the results of the investigation.

(Standard Medical Malpractice Interrogatory No. 43.)

Interrogatories to Plaintiff from Defendant

61. State chronologically and in detail:

(a) the cause and origin of the injuries alleged in the complaint;

(b) if you contend the injuries changed or worsened over time, state how and when;

(c) the course of the treatment provided by each defendant;

(d) each procedure that was performed by each defendant;

(e) the substance of your conversations with each defendant prior to and after each procedure or other treatment, including how the proposed procedure or treatment was described to you; and

(f) the extent of your knowledge of, and consent to, each procedure or other treatment. Identify all sources of information about the procedure or other treatment that you consulted before it was performed or rendered, including any sources on the Internet.

(Standard Medical Malpractice Interrogatory No. 61.)

62. With respect to defendant [insert name], describe in detail each act or omission that you contend constitutes a breach of the applicable standard of professional care for the Patient or that otherwise forms a basis for your claim against the defendant, and for each such act or omission:

(a) explain how you contend it caused or contributed to the Patient’s injuries or death alleged in the Complaint; and

(b) identify each person and document having or containing information that supports your contention.

(Standard Medical Malpractice Interrogatory No. 62.)

63. If you contend that any portion of any medical record, chart, or report is inaccurate, false, or altered:

(a) identify each document and each part of it that you contend is inaccurate, false, or altered, and

(b) as to each contention, state the factual basis for it.

(Standard Medical Malpractice Interrogatory No. 63.)

64. State the substance of all written and oral advice, instructions, and warnings you received from defendant [insert name] before and after each procedure or other treatment, and attach a copy of each written advice, instruction, or warning. If you no longer have the document, summarize your recollection of its substance.

(Standard Medical Malpractice Interrogatory No. 64.)