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RALPH REYNOLDS vs. JOHN EDWARDS, ETC., ET AL.
DEPOSITION OF DR. PETER M. LOTT
Taken on July 17, 2002

DIRECT EXAMINATION BY MR. SEIGAL

 

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DESCRIPTION

   
3 I was hired by Mr. Harry Nelson approximately October 7, 2001. I was asked to render a vocational opinion concerning future earning capacity in Mr. Reynolds' case.
6 I requested medical and employment records that were available from Mr. Nelson. I told him to send me those that were useful to me from a vocational perspective which are those which speak to physical functions, sitting, standing, walking and other things of that type.
7 I have no record on Mr. Reynolds' physical condition before the alleged incident. I asked for all of the records that spoke to that and I received nothing that spoke specifically of his medical history. I know from talking to him that he had back pain and that he had seen Dr. Williams previously. That's noted in my report.
8 I'm not in the business of rendering medical conclusions. Mr. Reynolds' physical condition before May 7, 2001 is not useful for me to render an opinion because I'm not a physician. The opinions that I formed in this case are based upon medical records that come after the accident.
9 I have no documentation that speaks to physical capacity that Mr. Reynolds did not have before the incident or were in any way limited before the incident. I'm not aware of any limitations to his ability to work.
10 What I know is that Dr. Cline on July 20, 2001 certified him as having a disability. That's what I know. The fact that this individual had experienced a fall on May 7, 2001 and that the lumbal myofacial strain was the diagnosis, that's really all I have.
11 That's correct, it is my understanding that that lumbar problem that Dr. Cline referred to on July 20th, 2001 relates to a fall that Mr. Reynolds alleges took place on May 7, 2001. That's what Mr. Reynolds has stated. The record does not speak specifically from Dr. Cline to causation at this point but simply speaks to physical limitations. Dr. Cline's admission note states that the patient is a thirty-six year old black male who injured himself at work approximately two years previously.
12 It's up to a doctor to determine what the causation is. It's up to me to determine the impact of whatever limitations are stated by the doctor on the ability to perform work and that's what I've rendered an opinion about.

 


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