I feel like I know who you are

Give example. However, it is your job to go through the medical records. The non-retained disclosure does not have to be specific like a retained expert. It only has to be general with some specifics. They are the treating doctor, so they can testify about anything in the their medical records.

Agreed, but you can't put everything in the disclosure, such as their social security number, etc.. that is why I asked for an example. The disclosure is not hard in my opinion as you merely summarize the opinion. The problem is a motion is brought every time by ID counsel. It is either to vague or they claim the language in the disclosure is detailed, so the doctor can't discuss common sense stuff not noted in the records. In addition, the opinion is always the crash caused the injury. Here is an example.

This individual is expected to testify as a treating physician and as a spinal and orthopaedic surgery expert regarding the spinal and orthopaedic injuries sustained, past injuries sustained, and present medical condition. In the event the Plaintiff becomes in need of future medical treatment or has a permanent impairment, this individual will opine as to need to a reasonable degree of medical probability. This individual using his expertise in spinal and orthopaedic surgery will opine as to the prognosis, disability, pain and suffering, disfigurement, causation, and the reasonableness and necessity of all care and billing as it relates to the Plaintiff, and to authenticate and verify the medical records and bills. This opinion will be based on his specialty in spinal and orthopaedic surgery, certification by the National Board of Medical Examiners, certification and recertification by the American Board of Orthopaedic Surgery, 22 years in practice, and familiarity with the Nevada medical community and understanding of the medical billing practices in Nevada by practicing in Nevada for many years. Pursuant to N.R.C.P. 16.1 (2)(b), the said witness, being an expert witness who is also a treating physician and thereby not retained or specially employed to provide expert reporting, will be testifying as to causation based on his/her diagnosis and treatment of the patient. Said expert’s opinion as to causation may not be blatantly stated within the witnesses medical records, however, it is said expert’s opinion that the medical care and treatment of Plaintiff rendered by expert and other medical providers upon which expert relied was a result of the subject incident. This opinion is to a reasonable degree of medical probability. Said expert’s chart with all relied upon medical records is available upon request and pursuant to a valid HIPPA authorization executed by Plaintiff. Witness is submitting a C.V., Fee Schedule, and testimony history. Further, this expert is expected to testify consistent with the medical records produced in this litigation which are allegedly related to the treatment of the Plaintiff for the subject incident, and other incidents having relevance to this action. Specifically this expert relies on the medical imaging, conservative case rendered, __________________, and all diagnostic testing related to spinal and orthopaedic surgery. The facts and opinions to which the expert is expected to testify include any and all facts and opinions in the said medical records, and that the medical treatment the Plaintiff received was reasonable, necessary, and caused by the incident set forth in the Complaint, and would rebut any opinions rendered by any witness disclosed by any party in this action that contradict the same.

Specific details are added in the blank space. Is that disclosure proper in your opinion? If not, what else should it say. Although, numerous judges have said it is proper.

Experts are not needed. I just say a bunch of big words and then hope the referee gives me the max $10,000 allowed in small claims court.

Of course he can. But only if he's properly disclosed as a non-retained expert, which includes disclosing those opinions, and providing the summary of the facts relied upon in forming that opinion. Otherwise, the treater is a lay witness, who can testify as to what he saw, what he did, but not to what his opinions might be.

I heart you 3:46.

Sincerely 5:46.