One of the questions that we frequently encounter from clients in preparing for their deposition testimony is whether their failure to recall prior physical complaints and treatments by their physician could result in dismissal of their claim. It is of particular concern when clients have had medical treatment for prior injuries such as whiplash, back and neck pain, disc injuries, spinal cord injuries and TMJ. Many clients have experienced complaints of pain for which they sought treatment from their doctor. When questioned about whether they had ever experienced such treatment in the past, many clients legitimately have a difficult time remembering that they had described such pain symptoms to their doctor. This is particularly so when the complaints resolved and were not a continuing issue in their life. In order to minimize the occurrence of this issue for our clients, we routinely obtain as many of their past medical records as we can locate. We require that our clients carefully review these records before their deposition is taken in order to help them recall such pain complaints and treatments. Despite careful preparation of clients for deposition however, this problem still arises when clients fail to recall these […]

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