1. Set Up Safety Rules at Defendant’s Deposition

2. Standard of Care Is for Safety
Q. Okay. And would you agree that one of the responsibilities of physicians acting within the standard of care is to protect their patients?
Yes.
Q. First, do no harm?
Correct.
Q. Secondly, don't add any additional harm if harm has already been done; true?
Q. There is nothing more important than the safety and wellbeing of the patient?
A. Agree.
Q’s by Jim Bartimus of Kansas City, Kirkeminde v. Midwest Dvsn-OPRMC, Dec. 9, 2014

3. Q. Sure. And your job within the standard of care is to try to fix it as best as possible? A. Yes. Q. And not to take unnecessary risk with a patient? A. I agree. Q. It's never the standard of care to needlessly expose a patient to risk, is it? Q. Medical records need to be accurate for the safety and wellbeing of the patient, don't they?
Q’s by Jim Bartimus of Kansas City, Kirkeminde v. Midwest Dvsn-OPRMC, Dec. 9, 2014