Here’s a tip: When deposing a doctor, or any other witness, Google their name and see if he or she maintains an official website. These days, almost anyone in business maintains a website. Doctors, retained testifying experts, contractors, fact witnesses, essentially anyone you might depose, likely has one. Accordingly, such sites can be mined for information prior to their depositions.
You’d be surprised at how much information doctors place online about themselves. This is not the type of personal information that one might find on a social media profile like Facebook. This is the public presentation of that person’s business identity. Accordingly, you might find biographical information, representations of their skill sets, or information about how often they do the type of work at issue in your case. You may be learn that the doctor actively solicits patients from lawyers or hawks his services as one who treats accident victims. If the doctor does that, such representations can be explored at the doctor’s deposition. Further, it is unlikely that the doctor may recall the precise wording of the representations on the website and will be unprepared to answer questions about them.
Other information may also be obtained. For example, you may learn the names of all of the staff members of a doctor’s practice, and thus be able to identify other potential witnesses.
So, for good measure, seek out the official website before your deposition. It might be worth it.