Litigation Packet

• 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]