sample cross examination of dr. barry jeffries:

Download Our Template Cross Exam of a Medical Expert

In our opinion, Dr. Jeffries has an obvious bias as a well-known expert witness. You must expose this bias when you cross-examine witnesses like him in court proceedings. We've created a template cross-examination for your next trial deposition of a medical expert like Barry Jeffries, MD. Our cross-examination of this medical expert, including his work in nuclear medicine and diagnostic imaging, covers:

• How much has Dr. Barry Jeffries, MD, made from defense medical reviews from 2015-2024 (nearly $4 million)?
• Dr. Barry Jeffries' testimony about the percentage of his reviews for the defense (99%) in insurance claims.
• Dr. Barry Jeffries has only found traumatic disc injuries in 20-30 of the 5000+ cases he has reviewed.
• Highlighting how rarely Dr. Barry Jeffries' expert testimony supports plaintiffs in car accident cases.
• Previous testimony from Dr. Barry discounting subjective patient complaints and diagnoses from treating physicians.
• Revealing Dr. Jeffries does not physically examine or treat patients. Nor does he speak to their treating doctors about diagnosis and treatment. Instead, he relies on medical reports from imaging equipment.

The goal is to cast doubt on the credibility of an expert specializing in nuclear medicine and diagnostic radiology. We want to show the jury that the expert's impressive credentials do not make him an unbiased medical expert.

However, in a trial deposition, you do not want to debate the science with an experienced medical doctor. Using this tactic often leads to a losing battle where you also look foolish to the jury. Maintain the high ground and hammer the biases in a short and succinct fashion.

Preview:

Trial Cross of Dr. Jeffries

IN THE STATE COURT OF HALL COUNTY

JOHN BROWN v. Robert Smith

Dr. Jeffries, I know you’ve been deposed many times. So, I don’t think I need to go over any ground rules. But certainly, if you need to take a break at any time, please let me know.

Bias re: Money & Numbers

1. Dr. Jeffries, would you mind telling the Jury how much you’ve been paid you To Date, including your time here?

  a.

2. And what are you charging an hour for your time today?

  a.

3. And when did that time start?

  a.

4. Through now?

  a.

5. Until When?

  a. 

6. Now you've been hired by lawyers to do medical, legal reviews well over 4,700 times, right - close to 5000?

  a.

  b. Per 2023.12.19 depo transcript (page 24)

7. And 95% of them have been for the defense lawyers like [defense attorney's name]?

  a.

  b. Per 2023.12.19 depo transcript (page 24)

8. And 99% of the cases you've actually testified for have been for the defense, right?

  a.

  b. Per 2023.12.19 depo transcript (page 24)

9. And in this case, you've been hired to provide testimony for the defense, for Defendant [defendant's name], correct?

  a.

10. You've been retained by Groth Makarenko Kaiser & Eidex more than 160 times, isn't that right?

  a. 

  b. Per 2023.12.19 depo transcript (page 25)

11. Lately, you've been testifying multiple times a week, isn't that right?

  a.

  b. Per 2023.12.19 depo transcript (page 25)

12. And in all these cases for the defense, you've only found evidence of acute traumatic injury in 20 or 30 cases, is that correct?

  a.

  b. Per 2021.05.27 depo transcript (page 51)

13. And 99% of the time, you have testified favorably for the defense, correct?

  a.

  b. Per 2017.09.20 jury transcript (page 193-194)

14. From 2015 to 2019 you made $2,489,059.34 from these film reviews, right?

  a.

  b. Per 2021.05.27 depo transcript (page 53)

15. In 2020, you made $505,815 from these film reviews, right?

  a.

  b. Per 2021.03.09 depo transcript (page 14)

16. In 2021, you made $601,037 from these film reviews, right?

  a.

  b. Per 1099s produced in 2023.12.19 depo transcript

17. In 2022, you made $655,208 from these film reviews?

  a.

  b. Per 1099s produced in 2023.12.19 depo transcript

18. That's $3,745,304.34 from 2015 to 2023 from film reviews?

  a.

19. That's nearly 4 million dollars from 2015 to 2023 that has nothing to do with...

Don't let defense experts mislead the jury unchallenged

The defense will do everything possible to undermine injury claims with expert testimony. If unprepared, their impressive credentials can improperly sway the jury despite obvious biases. You cannot allow defense medical reviews to go unchallenged.

Even though radiologists are medical doctors, they are not treating physicians. This means they do not physically examine or treat patients. They just review films and reports to produce their expert opinions.

Through cross-examination and leading questions, you can blunt or discredit the expert's opinion. Forcing them to focus on answering the question directly and not wavering is essential. Once the deposition concludes, you can obtain the transcript from the court reporter, preparing you for the upcoming trial.

Our free sample provides a blueprint on how to effectively cross examine a witness and win trial court battles. Their area of expertise covers various parts of the body and spans multiple medical specialties. Conduct a discovery deposition to determine the facts and biases. Then come back for your trial deposition to hammer just the biases and watch plaintiff verdicts increase.

Adaptable Blueprint for Any Case

The facts may vary, but financial bias and lack of diligence are recurrent themes for many defense experts. This cross exam template provides an outline to adapt to the witnesses in your specific cases. Swap out plaintiff names, defendant firms, doctors treated, and venue-specific information. The sequence of questions and blueprint of establishing bias remains the same.

Level The Playing Field Against Power Defense Firms

Large insurance companies have virtually unlimited resources to hire witnesses like Dr. Barry and fight claims. Face this challenge confidently, and do not let discouragement hold you back. Our template gives you a clear strategy to expose and disarm defense experts.

This approach is crucial, especially when dealing with experts in interventional radiology, who rely heavily on advanced imaging equipment. This medical imaging equipment which produces diagnostic imaging reports is nothing without physical examinations and patient feedback. So add this template to your quiver to take down defense medical testimony and get justice for your injured clients.

Need Support Or Have Questions?

Our goal is to equip plaintiff attorneys with the tools and knowledge to secure justice for their injured clients. We're happy to consult with you at any stage of litigation. And we welcome the opportunity to partner on your cases. We encourage you to delve into our assortment of free resources and learn more about effectively litigating personal injury cases.

If you need additional resources, have questions, or need help with a specific case, don’t litigate alone! Schedule a free strategy session today. Together, we can overcome defense roadblocks, secure fair verdicts, and get your clients the compensation they deserve. We're here to help.

DISCLAIMER: The views and opinions presented in this article are intended for informational and educational purposes. They reflect the author's personal viewpoints and interpretations, not assertions of fact. While it discusses a well-known expert witness, this article makes no claims about the veracity or applicability of their work. Readers are advised to engage with a variety of sources and consult with a qualified professional before drawing conclusions or making decisions based on the material provided herein.