Expert Witness Report (Medical Opinion)

Case: [case caption, venue, case number]

Expert: [name, degrees, specialty]

Retaining Party: [party name and counsel]

Report Date: [date]

(Maintain neutral, non-advocacy tone throughout. Define medical terms at first use. Cite sources for every factual assertion using document name, date, and Bates number if available.)

1.0 Assignment

[Engagement role: standard-of-care review / causation analysis / damages and prognosis assessment / other] (Identify the specific medical questions to be addressed and the relevant timeframe, including date(s) of incident or care at issue. If questions are framed in legal terms, restate as the medical components to be evaluated.)

• [Question 1 to be addressed] (Number questions sequentially to align with Section 5 opinions.)
• [Question 2 to be addressed]
• [Additional questions as needed]

[Jurisdictional probability standard if required, e.g., "to a reasonable degree of medical certainty" or "more likely than not"]

2.0 Expert Qualifications

[Qualifications summary] (3–5 sentences: current clinical role, board certifications, active license status and jurisdictions, relevant clinical experience specific to the issues in this case, and any pertinent medico-legal or guideline development experience.)

(Full curriculum vitae attached as Appendix A.)

3.0 Materials Reviewed

(Group by category. Include document type, date, source/author, and Bates range if available. Note whether primary data vs. report was reviewed. List requested but missing materials separately.)

• Medical Records
  • [Record type; date; source; Bates]; [primary data / report only]
• Imaging
  • [Modality and study; date; facility; Bates]; [images reviewed / report only]
• Depositions/Statements
  • [Deponent name; date; role; Bates or transcript reference]
• Policies/Guidelines
  • [Policy/guideline name; issuing body; year/version]
• Scientific/Medical Literature
  • [Citation: author, year, title, journal]
• Other
  • [Item type; date; source; Bates]

Materials requested but not received: [List outstanding items and dates requested, or "None"]

4.0 Summary of Relevant Facts

(Provide a neutral, source-cited narrative. Do not include argument or conclusions. Attribute disputed facts to their source, e.g., "Per patient report...")

Patient overview: [age at incident; sex; relevant baseline health and functional status; key comorbidities; relevant medications or devices] (Cite source for each fact.)

Chronology of events:

• Date: [date] | Event: [encounter/procedure/communication] | Key Findings: [objective findings, measurements, results] | Source: [document; Bates]
• Date: [date] | Event: [encounter/procedure/communication] | Key Findings: [objective findings, measurements, results] | Source: [document; Bates]

Pertinent objective data: (Key imaging, laboratory values with units and reference ranges, operative findings, or pathology relevant to the opinions.)

• [Data type; date; result with units and reference range; Source: document; Bates]

5.0 Medical Opinions

(Organize opinions to mirror numbered questions in Section 1. Use jurisdictionally appropriate probability language. Address timing, mechanism, alternative explanations, and applicable standards/guidelines. Identify contrary evidence and explain reconciliation.)

5.1 Opinion 1

Opinion: [One-sentence conclusion stated to the required standard, e.g., "It is more likely than not that..."]

Basis:

• [Reason tied to specific facts/data from Section 4 with citations]
• [Reason addressing timing/mechanism with citations]
• [Reference to applicable standards/guidelines or literature with citations]
• [Consideration of alternative explanations and why less likely, with citations]
• [Acknowledgment of contrary evidence and reconciliation, if applicable]

Assumptions: [Explicit assumptions required for this opinion, if any] (Omit if none.)

Limitations: [Missing information or unknowns that could affect this opinion] (Use standard phrasing: "This opinion is limited by the absence of [item]; if later produced, my opinions may require supplementation." Omit if none.)

5.2 Opinion 2

Opinion: [One-sentence conclusion stated to the required standard]

Basis:

• [Reason with citations]
• [Reason with citations]
• [Reason with citations]

Assumptions: [Explicit assumptions, if any]

Limitations: [Missing/unknowns and potential impact, if any]

(Add additional numbered opinion subsections as needed to correspond to Section 1 questions.)

6.0 Attestation

I, [name, degrees], hereby attest that the opinions expressed in this report are my own, are based on the materials identified herein, and are offered to a reasonable degree of medical [probability / certainty] consistent with the requirements of the jurisdiction. My compensation is at my standard rates as set forth in Appendix D and is not contingent on the outcome of this matter. I understand that my duty is to the court and that this duty overrides any obligation to the retaining party.

[Jurisdictional declaration language if required]: I declare under penalty of perjury under the laws of [jurisdiction] that the foregoing is true and correct.

Signature: ________________________________

Name: [name, degrees]

Credentials: [licenses with numbers and jurisdictions; board certifications]

Contact: [business address; phone; email]

Date: [date] | Location: [city, state]

Appendices

• Appendix A: Curriculum Vitae
• Appendix B: Prior Testimony List [timeframe per court rules, typically 4 years]
• Appendix C: Publications List [timeframe per court rules, typically 10 years]
• Appendix D: Compensation Schedule