Charts and diagrams permit jurors to easily see how standard medical procedure works and how your client followed that procedure. Begin by detailing standard procedure, using charts as suggested above. Go back to each point on the chart where your client deviated and explain why your client did not follow procedure. Demonstrate how standard procedure is just that, standard, and does not take into account different individual parameters. It is important to demonstrate that every deviation made was in the best interest of this patient.
Jurors routinely find against doctors who fail to order tests or fail to read test results.
Jurors are particularly disapproving of doctors who order tests but fail to request their results. As with the recommendations for standard procedure, emphasize the ways in which your client requested and evaluated the appropriate tests. The important message to the jurors is that your client knew of the tests and would have used them if the doctor had believed they were in the best interest of the patient at the time. Jurors often have difficulty understanding the critical nature of time in medical procedures. Use visuals such as time lines to vividly illustrate what time factors were being considered and how your client was factoring them into his or her decisions.