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Separate, tab and label the different sections of the chart!
One big section,
with sub-tabs, for each hospital admission, one for each doctor's office.
Put everything in three-ring binders. |
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Send everything your expert needs to give you a solid opinion. Nurses notes can be a treasure
trove.
Don't
pay to have a surgery-gone-bad reviewed until you can send the operative-report. |
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Send a list of the records you put in the package. |
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Send a copy of your copy the records. |
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Summarize the facts in the case; help your expert get up to speed quickly. |
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If your client's version of the facts differs materially from the chart's,
be sure the reviewing doctor knows your client's version of the facts. |
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Consider asking your expert specific questions you need answered. "Did
cutting the bile duct fall below the standard of care?" "Was Mrs.
A adequately informed of the risks of the surgery?" |
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Read the autopsy yourself. Don't sink thousands of dollars in a wrongful-death-by-heart-attack
case only to have your expert point out that page one of the autopsy report
also shows widely metastatic cancer and a six month expected survival. It
happens. |
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Beat back your urge to date order the chart as a whole. Date order
is how you've been trained to think, it is not how doctors think. |