Personal phone call 14:24- Chime reports problems with balance and ringing in ears - Doesn’t make it into doc’s report. 15:04- 15:40- still have problems with balance- “happens in the shower” - No follow-up - Report Page 2- Last paragraph of “ongoing complaints” “But not at other times” Shoulder Lower back Left leg knee down to foot Left shoulder rotation and stiffness You say in your report in various parts example on Page 8, that Mr. Chime’s inconsistency as to his memory of events “supports his lack of credibility”. - You understand that Mr. Chime claims he suffered a traumbrain injury right? o You didn’t know before, but you do now? So do you withdraw your criticism about his credibility contained in your report? - You don’t dispute that Mr. Chime injured his head in this crash do you? o Hematoma and a laceration to his scalp that required several staples, right? - You have no opinion about whether or not he suffered a brain injury right? o Assuming he did suffer a brain injury, would it surprise you if he had difficulty recalling past events? Why factor that into his credibility? Were you asked by defense counsel to review Mr. Chime’s STD history and medical treatment? - Have you ever found STD records to be relevant to your orthopedic treatment of any of your patients? o So, as you are reviewing mixed records from Kaiser, once you see at the top of the page, or once you identify, “hey this is something having to do with sexual health”, why keep reading? If you felt the need to read it, just to be sure, but it had no relevance, why include a summary of that in your orthopedic report? Page 37- “At most, Mr. Chime may have sustained a minor concussion.” - Did you conduct a neuro exam on Mr. Chime? - Did you do any neurological testing on Mr. Chime Page 37 “There is absolutely no objective evidence based on the mechanism of injury that he sustained any significant concussion or loss of consciousness” - Did you do a reconstruction of the crash? - Conduct a biomechanical analysis of any kind? - What was the delta V? - What kinds of forces did Mr. Chime experience during the crash? - The crash photos don’t support a mechanism of injury for a head injury? o Neck, Back, shoulder? Page 38 Neuropsychiatric and psychological evaluation and audiology were not necessary - You’re the bone guy right? o You’re saying that you are in at least an equal position to opine on whether or not Mr. Chime’s audiology symptoms are related to this crash as Mr. Chime’s audiologist? o You’re saying that you are in at least an equal position to opine on whether or not Mr. Chime’s Neuropsychiatric symptoms are related to this crash as Mr. Chime’s Neuropsychiatrist? o You’re saying that you are in at least an equal position to opine on whether or not Mr. Chime’s Neuropsychiatric symptoms are related to this crash as Mr. Chime’s Neuropsychiatrist? Bills - Let’s look at the ambulance bill- $1,678.00. o Which part of this do you claim is unreasonable? Let’s look at the UCLA emergency room bill- $6,195.00. o Which part of this do you claim is unreasonable? That’s $7,873.00 when combined. Page 39 “Reasonable cost of medical treatment for Mr. Chime after the 2017 motor vehicle accident would be in the range of $1,000 to at most $5,000 based on the objective evidence, which I have reviewed.” Medical services by Page 38 “The initial evaluation in the emergency room appears to be medically necessary. He would have required several follow-up visits regarding the laceration follow-up and removal of staples.” Were you aware that in 2018, the CA Court of Appeal threw out your trial testimony in the Miglas v. AAble Inc. case because it found that you were unqualified to give a biomechanical opinion as to injury causation based on your review of crash photos in that case? Exhibits: 1) Ambulance Bill 2) UCLA ER Bill 3) Exam Audio a. https://drive.google.com/drive/folders/1mZpyQr-rTUDcuKxNSC1PhuqA9ONptnk?usp=sharing
