Lay out the time line, everyone who treated her, that they did, and the alleged negligence. Be prepared to write it on the board.
What did Davidson testify to when he was deposed? Why was the deposition postponed?
What order did the court enter on 15 July 1992?
What did plaintiff do about Davidson?
What was the 8 January 1993 Consent Agreement and how did it affect Davidson?
When did plaintiff name Davidson?
What did the defendant do and what was the court's response?
What happened on 15 November 1993?
What did the court do?
What is a motion in limine and what was the outcome for plaintiff?
What was plaintiff's objection to defendant's use of medical journal articles?
What is an "offer of proof" and why are they done?
What is the standard for determining if a trial judge has abused his discretion as regards excluding testimony?
What sanctions are available for the trial court if a party does not comply with the discovery orders?
What was plaintiff's reason for not disclosing Davidson?
Why did failing to disclose Davidson hurt the defendants?
Was it error to exclude Davidson?
Why was plaintiff's complaint about the admission of the medical texts ignored?
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