Neuropsychologist Testimony

A. Background & Qualifications

1. Name

2.. Occupation

3. Where do you practice

4. Doctor, could you tell the jury about your educational background.

5. Are you a licensed clinical psychologist

6. Are you a board certified psychologist?

7. What does it mean to be board certified?

8. How many board certified psychologists in the country

9. Do you have a specialty?

10. What is your work experience

11. Have you written any articles for professional journals or professional publications in the field of clinical neuropsychology?

12. Have you had occasion to speak to any professional groups in your field.

B. Neuropsychology

1. What is psychology

2. What is neuropsychology

3. What is neurology

4. How does the field of neuropsychology interrelate with the field of neurology.

C. Head Injury

1. What is the brain; how does it function?

2. What is a head injury?

3. What happens to the brain when an injury like this occurs?

4. How are injuries like this caused?

5. What is a neuropsychological evaluation?

6. What kinds of things does such an evaluation show?

7. Is it within the expertise of neuropsychology to make evaluations regarding the presence of brain injury.

8. As a neuropsychologist, do you personally specialize in evaluating the effects of head injury on  human brain function?

9. Do you evaluate people, on a regular basis, who have sustained head injuries?

10. What are the symptoms of ahead injury?

(a) Physical symptoms

(b) Behavioral symptoms

(c) Cognitive symptoms

11. What do you mean by the word "cognitive."

D. Evaluation of Client

1. Have you evaluated Mr. Tread Smith

2. When was the first time that you saw him?

3. Through the course of your treatment of Mr. Smith, was he cooperative?

4. How was he referred to you?

5. Did you take a history from Mr. Smith?

(a) What was that history?

6. Did you receive any information from any other source?

(a) Medical records

(b) Information

(c) Interviews

7. Did you make any behavioral observations regarding Mr. Smith from your interview with him?

8. What did these observations indicate to you?

E. Testing

1. What did you do after your initial interview with Mr. Smith?

2. What areas of functioning were tested.

3. Who is in charge o interpreting the data provided buy these tests.

4. Are these tests given under your direct supervision and control?

5. (In each area of functioning, describe tests administered).

(a) What did Mr. Smith's testing in this area reveal.

6. What other testing or evaluation did Mr. Smith undergo?

(a) What were the results of these?

F. Diagnosis - Assessment

1. Does your work as a neuropsychologist include making assessments of brain injury.

(a) Approximately how many times have you made such assessments?

2. Based upon the history, other information received concerning Mr. Smith, and the testing and test results, did you form a diagnosis or assessment regarding Mr. Smith.

3. Based upon this diagnosis, how would Mr. Smith's brain injury effect his life?

(a) Interpersonal relationship.

(b) Work life

4. Are there cognitive impairments?

(a) What?

G. Treatment

1. Did you recommend treatment for Mr. Smith. What did that consist of?

2. Did you provide any vocational guidance or assistance? Describe.

3. What did you do in following Mr. Smith's work activities during the time you have treated him?

4. When was the last time you did a formal evaluation of Mr. Smith?

5. What was his condition at that time?

6. Would you expect improvement in the future?

H. Opinion Questions

1. Do you have an opinion, based upon a reasonable degree of neuropsychological certainty as to whether the impairment you have described will be permanent?

2. On what do you base that opinion?

3. What is an impairment rating?

4. Have you determined an impairment rating for Mr. Smith based upon his brain injury.

5. Will this impairment get better or worse in the future?

6. Do you have an opinion based upon a reasonable degree of neuropsychological certainty as to how Mr. Smith's brain injury will effect his employment in the future.

7. Do you have an opinion, based upon a reasonable degree of neuropsychological certainty as to whether Mr. Smith will ever achieve full-time employment.

(a) As a neuropsychologist are you commonly called upon to give suggestions regarding the type of employment or retraining program that a patient might be suitable for?

(b) Do you have any suggestions regarding Mr. Smith?

(c) Are you familiar with his present employment. How do you view this?

8. Do you have an opinion, based upon a reasonable degree of neuropsychological certainty as to whether Mr. Smith will require additional treatment and counseling in the future? Detail with chart.

I. Statement for Services

1. Doctor, have you rendered a bill for services rendered to Mr. Smith?

2. Amount, services covered.

3. Is this bill reasonable for like services in this area?

4. Were these charges necessary as a result of Mr. Smith's injuries?

J. Hypothetical Question

Doctor, please assume the following facts to be true: on March 1, 1998, Mr. Smith was involved in a head on collision with a commercial truck, which collision rendered him unconscious. He received a number of injuries, including a fractured hip and what his orthopedic doctor noted as a closed head injury. Prior to this collision, Mr. Smith had full-time employment including management and supervisory duties and earned in excess of $20,000.00 per year. He had no intervening injury between March 1, 1998 and the time of your initial evaluation of him.
Based upon these hypothetical facts, together with all of the history testing, treatment and personal knowledge you have gained about Mr. Smith, do you have an opinion, based upon a reasonable degree of neuropsychological certainty as to the connection between the collision of March 1, 1998 and Mr. Smith's brain injury?