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RT: 07:37
9:25A.Yes. I do have a spine model here.
10:1Q.Can you -- can you show us, yeah, bring it to the view.
10:3A.Yeah. Let me see.
00:00 / 01:19

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Page 9
25A.Yes. I do have a spine model here.
1Q.Can you -- can you show us, yeah, bring it to the view.
3A.Yeah. Let me see.
4Q.Thank you, Doctor.
5Now, with regard to your treatment — can you tell us generally what areas of her body you treated.
8A.So, really, three areas that we focused on.
10These bottom two levels of the lumbar spine (so L4-5 and then L5-S1).
14...it's basically the side of the hip.
15Q.All right. And can you kind of go into a little more detail as to what specifically is there on the diagram?
18A.Absolutely.
20So basically this is a model of the low back, the lumbar spine. Essentially we have the central canal, which is the spinal cord.
22Off of the spinal cord we have these nerve roots that are exiting.
23These nerve roots go to the low back as well as the buttocks, legs, feet — all the way down.

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1Select testimony

Zuch, Issak M.D. — Vol. 1Page 46
1

Q.Doctor, I want to ask you about the treatment you recommended for the patient.

2

A.Sure.

3

Q.When did you first evaluate her?

4

A.I saw her initially in March of 2022.

5

Q.What treatment did you recommend?

6

A.Physical therapy twice weekly for eight weeks.

7

Q.Did you discuss activity restrictions?

8

A.We also discussed activity restrictions at work.

9

Q.What restrictions did you recommend?

10

A.No heavy lifting over 15 pounds and limited prolonged sitting.

11

Q.For how long?

12

A.Initially for six weeks, then we reassessed.

13

Q.Did you prescribe any medication?

14

A.Yes. A short course of anti-inflammatory medication.

15

Q.Any referrals outside of physical therapy?

16

A.Not at that initial visit, no.

17

Q.Did you order any imaging?

18

A.An MRI of the lumbar spine was ordered.

19

Q.When did you receive those results?

20

A.About ten days after the order.

21

Q.Did the imaging change your treatment plan?

22

A.It confirmed the clinical findings we had already discussed.

23

Q.Any further questions on treatment?

24

A.No.

25

Q.We will mark Exhibit 12.

2Created Clips

Treatment Plan

46:6–46:7 · 00:18

Activity Restrictions

46:7–46:8 · 00:11

Notice

124:18–125:4 · 00:22

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Anthony Brigham

Defendant witness, elevator tech

Suggested Testimony

All (28)Admissions (12)Impeachment (6)Damages (7)+ More

Admissions (12)

Safety memo was received on May 12, 2022.

Page 45:1–45:5

00:38

You were aware of the broken guardrail.

Page 78:8–78:18

00:42

The procedure was not followed that day.

Page 112:3–112:7

00:51

Show all 12 ∨

Impeachment (6)

Contradicts prior testimony on timeline.

Page 156:10–156:18

00:47

Contradicts written report dated 6/4/22.

Page 203:2–203:9

00:33

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Damages (7)

Lost wages discussed.

Page 311:4–311:9

00:41

Future treatment was recommended.

Page 347:12–347:17

00:39

Show all 7 ∨

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