33rd Annual Advanced Evidence and Discovery, State Bar of Texas, 2020
Dr. Doe, if you will please raise your right
Q. Doctor, tell me, how much do you charge for
a rotator cuff surgery?
A. You know, I have no idea. You will need to
ask my billing manager, Martha.
Q. Well, do think that $175,000 is a reasonable
and customary charge for a surgery facility in
A. I really do not know.
Q. Well, is $100 a visit a normal charge for postsurgery physical therapy.
A. Again, quit pestering me. I have no idea.
Q. Doctor, how do you even run a business?
A. I don’t. I run a profession. I hire others to run
How many times have you asked a doctor during a deposition about medical expenses, only to get befuddled by the absolute total inability to have any idea of his own billing practices, much less those of other
medical professionals and subject areas?