The Plaintiff (patient) alleges that on July 3 and July 4, the Defendant (PT) was negligent in performing range of motion exercises on the post-surgical knee when the PT knew to do so was contraindicated. The Plaintiff also claims that the PT would have known that such range of motion exercise was not indicated if the PT had noticed the immobilizer, which extended from the patient's buttocks to her toes. It is further contended that the Defendant PT's improper therapy treatment caused harm to the patient's repaired medial collateral ligament, which later became infected. As a result of this improper treatment, the Plaintiff required another ligament repair surgery, multiple debridement procedures to address the infected knee, and a total knee replacement. The Plaintiff is claiming persistent, permanent knee pain and limited mobility, with medical expenses of $750,000.

The Defendant PT claims that the disruption to the Plaintiff's medial cruciate ligament repair was caused by the Plaintiff's fall at home on July 23, not the therapy rendered. There is no mention in the medical records of any problems with the knee until after this fall. The knee was documented to be intact on a July 4 post-op visit with the surgeon; no complications noted in the medical record in a second follow-up visit on July 16. Instability of the knee was first recorded on July 24, one day after the fall at home, and the surgical wound infection diagnosed a later in September. The PT denies that the infection was connected to the physical therapy treatment and disputes the Plaintiff's claim of permanent knee pain. The PT argues that the total knee replacement should have resolved any knee issues. Plaintiff is seeking $2.7 million to settle the suit.

Defendant's (PT's) attorney should be prepared to depose the plaintiff.

Please let me know the questions pertaining to this case which would help the defendant attorney frame the questions to depose the plaintiff. The questions should involve medicolegal and ethics perspective .