Thoracic Outlet Syndrome Thoracic Outlet Syndrome/Brachial Plexopathy. In Memory Of DeAnne Marie.


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Old 10-31-2007, 01:24 PM #1
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Attention List of questions for deposition...

Hi Everyone,

Was anyone given a list to fill out of the things they do in daily life that have been affected by their TOS for a deposition, or anything along those lines? I have been asked by my Dr. to write down those things and the bodily changes that occur when I do them. I also need to provide the amount of time I can do the task before I must stop.

I am afraid I will forget something significant with out a list. I'd appreciate it of anyone could help.

Thanks,

Cala
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Old 10-31-2007, 02:21 PM #2
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If nobody has a list for you -

If I had to do that, I would start with when I wake up in the morning and proceed in sequence thru a typical day, then add less frequent errands and any other activities at the end.

Maybe record it, or use voice recognition software to do it??
- make sure they know that it was used and why - you couldn't write/type all the info by hand!
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Old 10-31-2007, 07:50 PM #3
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First off, do you have an attorney? The attorney should review and Ok these questions before you answer them, as occasionally they cross boundaries into things that aren't allowed - even by our own docs.

After that, the docs are usually looking for "Daily Activites of Living" which if you do a yahoo search maybe that will help you. My nurse has a list which includes bathing routines, eating, meal prep, dressing, and then goes on from there to house work, and bills, and don't forget things like taking care of your car or taxes. I don't know what or how you're limited. I can't cut a sandwich in half more than once or twice, and even if I can do it once, then swelling starts - and usually my third day is the worst day after an outing or event like trying to do laundry or change my own bed. It's so hard to describe these things in the way a usual ORTHO problem is described. Those are "I can't" when ours are more like "If I do this, then this will happen"...and even then, it depends upon where and how I'm in a flare. I don't even have a typical day, because I only sleep every third night.

So just do your best, and maybe ask if you can talk to the doc's nurse FIRST and explain how the TOS works and ask her, how do I answer "x", when this is how it works?

I hope this helps. I just remember from depositions, don't say "I can't" if it is that you can do it, but it just is painful, causes more pain, etc. Instead say, "oh, I don't want to do that cuz then my pain goes from 5 to 9 within a few hours..."

Again, hope this helps. Please feel free to post a question that troubles you. We all learn from this.
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Old 10-31-2007, 07:51 PM #4
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yes, and if you can't write like me, make sure you identify who wrote the answers our for you and why!
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Old 11-01-2007, 11:23 AM #5
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Definately get an Attorney if you can ! I just went thru that just recently ( for the 2nd time in 4 years ) and my Attorney and I together went thru it and HE wrote it down.. The others are right .. Start from you get up in the morning and so on... Don't be afraid to say " I rest alot" or "I do nap" during the day.. be as honest as you can be.

Good Luck to you !

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Old 11-02-2007, 01:38 AM #6
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I made a list like this. It was helpful to work from the list w/my PT and I compiled. PTs compile a list like this to do an initial eval and then to get add'l visits approved. I also walk thru the day. Look at the list a lot while compiling. When it's done bring it to the depo. Tell them TOS affects your thinking (as do your meds for TOS) and that you need to refer to it. The good news is that they will later ask to have a copy of the list. This is good for you. Of course you would forget things if you appeared w/o a list.

Anything from memory or foggy mind from pain, limits in chopping, stirring, holding heavy pot or even simple plate, sitting, holding book, how many pages you can read now vs. before, how long you can go out, pushing a shopping cart, lifting the groceries or other items you shop for, carrying a gallon or quart of milk or your purse or laptop or suitcase, cooking tasks, washing dishes, self-care, ... how much you can do work tasks, sit at computer, file, handwrite. Ability to take classes or do your hobbies. HOw you sleep now-less or wake w/pain or flare... How long you can drive, hold steering wheel, ride in car. How long you go w/o pain meds. How less dependable you are as you can't always predict when you will flare. The list can be broken down to groups of tasks: ADLs, work tasks, enjoyment of life, care for family... Everything from exercise, hiking, ability to take trips, museum or theatre going, church, other social things and your enjoyment of life from bowling to billiards to holding your child or grandchild-whatever it limits or prevents you from doing that you were doing prior. Career networking or career/job activities like attending classes or on work softball team...handwriting in a seminar or at a work meeting...more than 4 sentences or 4 minutes...whatever you did. Break it down to tasks. You can quantify before vs after when necessary. You design how it works, there is no right way to convey the info. unless your atty guides you. (Rode bike 7hrs/day on wkends or tours before and to and from work 5 miles each way; only 5 mins now before forearms pain, get numb, cramp, turn blue... whatever your sypmptoms are.)

Also emotionally how the TOS, sleep disturbance, meds, work disturbance may cause depression, emotional pain... less social interactions..difficulty with family...need for handicap status or help with tasks. And that you have to pay to get tasks done or you have to ask family or friends... But list the emotional stuff only if you clear it w/atty and if you are choosing to make a claim for that. If so you may have to open yourself up more than you'd like.

If you have plenty of time you can add things as you think of them. Once you start your list you will think of things to add. And of course check with your attorney but start jotting things down for yourself right away. Don't get too overwhelmed by this. The PT does one for their purposes in one session and then writes up an initial report. Realize that it can be very emotional to see how the TOS is truly affecting your life but try to stay focused. And remember that your list won't be published. It doesn't have to look pretty; just make it as complete as possible. And you can handwrite things in at the last minute. If it's not succint or beautifully organized it does not matter.

Good luck!

Last edited by fern; 11-02-2007 at 01:59 AM.
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Old 11-02-2007, 06:47 AM #7
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One thing I forgot, which most people are too embarrassed to even discuss:

sexual dysfunction due to TOS

In CA, w/c, it is I guess of some importance now. (told by others) So description of what now is changed / gone is important.
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Old 11-03-2007, 01:17 PM #8
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I'm not sure what type of case you have, WC or PI, but discuss this stuff w/your atty. Know that any topic you introduce are ones that you are opening yourself up to. The atty and you will decide what type of claims you are making and then whether or not to include stuff like sexual disfunction or emtional issues.
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Old 11-04-2007, 01:24 PM #9
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Default Thanks so much!!

Wow! Thanks to each and everyone for all of the answers! Very helpful, I must say!

I have an attorney, and I will ask about what information I should and shouldn't provide.

The suggestion to ask my P.T. was a great one. I'd have never thought of that.

I really appreciate all the responses!

Thanks again!

Cala
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Old 11-11-2007, 07:49 PM #10
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bump for C.
I thiink there's a lot listed here for you to create your own list. It's really about your body. I don't think there is a template. Just begin; it's not that difficult--if you are not in a big hurry.
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