surgery on Peter's January 4, 2006 examination. He estimated that if Peter has to undergo arthroscopic surgery in the future it would cost around $20,000 or between $12,000 to $15,000 based on surgical and hospital fees.
During cross-examination, he was asked about his report of January 4, 2006 where he wrote it was unknown whether any future problems might arise. When asked why now four days before trial he testified Peter will likely have future problems, he said it was unknown but if it was stated in medical-legal terms, he would say it was a probability. He explained he did not know for certain but if the lawyers had to hear it one way or the other, he had to say there was a probability it would be necessary.
Thedoing orthopedics for six months. He has problems with pain when he has to hold his arms out in front of him. A normal surgery day is 10 hours and if on call, he could spend the entire night in the operating room.
Dr. Robert D'Ambrosia explained that Peter would have problems with activities of pushing forward and holding his arms above 90 degrees in surgery. Upon entering the operating room, a surgeon's hands must remain above chest level (above 90 degrees) the entire time.
Peter testified that he has had difficulty using a saw during surgery. On one occasion, he unsuccessfully attempted a hip relocation in the emergency room. He had an emergency room physician take over. On another occasion, he could not do a hammering procedure with his