Understand the Motivations and Relationships

Defendants - Structure of Health Care Delivery and Finance

Who is making money?

Who is pay for the care?

What are the relationships between the players?

Plaintiffs

Who are all the players?

Which are injured?

What are the relationships?

What are the conflicts?

Who can you trust?

Proof = Facts

Records

Hospital records

Chart

Nurses' notes

Physician's notes

Physician's orders

Vital signs

Tests

Consent forms

Off-chart records

Private notes by staff

Cardex

Pharmacy records

Lab records

Risk management

Routine

Privileged

Billing office records

Physician office records

Patient charts

Appointment books

Any other records

Physician's personal diary and records

Pharmacy records

Independent lab records

Fact Witnesses

Who knows something?

Who did they tell?

Timeline Analysis

Grid

Who knew what and when?

Be able to show the jury the timeframe

What was the negligence?

Systems errors?

Individual negligence?

Cover-up?

Bad faith?