Publications

Litigation Packet

Litigation Packet

Surgical Negligence: Retained Towels and Sponges

Pages1760
CreatedJun 20, 2017
$325.00
Delivery method: Download
  • Focuses on cases involving significant injuries as a result of a surgical towel or sponge being left in the abdomen following surgery
  • Sample complaints, interrogatories, requests for admissions, requests for production of documents, and plaintiff and defense motions for summary judgment and reply memoranda
  • Plaintiff’s response to defendant hospital’s memorandum for in camera inspection of peer review documents
  • Jury instructions on foreign object counting and res ipsa loquitur
  • Plaintiff’s closing argument transcript
  • Deposition transcripts and summaries from several defense and plaintiff expert witnesses and defendants
  • AAJ Education speaker papers outlining the players in operating room negligence and apportionment of liability, verdicts and settlements, medical glossary of terms, and abbreviated medical journal survey

[Deposition summary accompanies each deposition transcript]