Yes, absolutely. In some of the shorter statute of limitation cases, victims may have to commence an action much quicker than their bodies have healed. This is particularly true for catastrophic injuries like traumatic brain injuries, spinal cord injuries, blindness, burn injuries, and other serious damages. When this happens, the defense side will have an opportunity to continue to collect your additional medical records. This is because a plaintiff has a continuing obligation to notify the defense of your new medicals. If surgeries are scheduled for years into the future, treating physicians or medical experts could testify what the surgery is, what the likely outcome is, and why it is scheduled for a date so far in the future. Generally, if a healthcare provider can establish with medical certainty that the surgery or procedure will occur and that it is necessary, a jury and insurance may consider this in assessing damages.