Per your request, I have reviewed the files regarding the care Jane Doe and what follows is my expert opinion based on may review of the records provided.

I am Board Certified by the American Board of Obstetrics and Gynecology  and in Female Pelvic Medicine and Reconstructive Surgery. I had extensive pelvic surgery training in residency with recognizes experts in the field. I also have extensive training and experience in minimally invasive surgical techniques. I have had twenty-two years of private practice experience performing and teaching these surgeries. I currently devote over 90% of my time to clinical practice, and the remaining time to teaching residents, medical students, and nurse practitioner students. I currently perform over 200 complex pelvic surgeries per year, including prolapse, incontinence, complex benign gynecologic procedures, and minimally invasive surgeries. I have been performing office and hospital hysteroscopic surgeries since 1995.

What follow are the summary of care on and my opinion regarding her care.

In reviewing the medical records, I can render an opinion with reasonable degree of medical certainty that Ms. Jane Doe care was well within the medical standard of care. Her care followed guidelines set forth by the American College of Obstetricians and Gynecologists as well as the American Urogynecologist Society. She certainly appeared to perceive a difficult recovery but there are no records to establish a departure from standard of care.

Ms. Jane Doe presented with a history abnormal bleeding and fibroids. She has appropriate preoperative evaluation with endometrial biopsy. She subsequently proceeded to hysterectomy and was appropriately co-manage with a general surgeon to treat her extensive abdominal adhesions, which again showed good judgement by the gynecologic surgeon in the approach to the hysterectomy. Dr. Doe again showed good judgement by the gynecologic surgeon in the approach to the hysterectomy. Dr. Doe then chose to perform a supracervical hysterectomy which was prudent in the patient that had extensive adhesions and, presumably, limited surgical visualization. By not removing the cervix, Dr. Doe would not have compromised anatomic support of the vagina. The patients’ s post-operative course may have been complicated by more pain because of the extensive pathology encountered in her surgery. There did not appear to be any other reason for her post-operative course. The fact that Dr. Doe left for vacation the day after surgery is not an indictment for poor care, albeit may have reflected poor patient communication.

The subsequent occurrence of prolapse can only be explained by two theories. The first is that they enlarged fibroid uterus combined with extensive abdominal and pelvic adhesion gave a false sense of pelvic floor support by not allowing the prolapse to be clinically apparent. The second theory would be that the prolapse was not diagnosed or appreciated on clinical exam prior to surgery. I have extensively reviewed the records and have not found a documented pelvic exam immediately prior to surgery. There is an exam form 2013 in the document which did not indicate any pelvic prolapse. Dr. Doe documents that an exam was done, and transvaginal ultrasound was performed that did not comment on the presence of absence of pelvic prolapse of any type. It is also not documented that the patient complained of urinary incontinence of prolapse symptoms prior to the surgery.

Ms. Jane Doe alleges how she felt “violated” with physical therapy. Physical therapy is the first line of treatment for prolapse and urinary incontinence by several guidelines. The Physical therapy described was standard protocol. The patient had an opportunity to decline. I have had multiple patients that opted to not have internal manual therapy performed for a variety of reasons.

In summary, it is unfortunate that Ms. Jane Doe experienced a difficult and complicated course of care. In my expert opinion, Ms. Jane Doe received appropriate and timely care and management.

All my above opinions are expressed to a reasonable degree of medical certainty. I reserve the right to amend these opinions if additional information becomes available.

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