The questions marked with an asterisk are taken from the judgment of Charles J in A Local Authority v K, D & L (supra) & those marked with a # are suggested by the Family Justice Council / Chief Medical Officer)
Please detail any medical difficulties experienced by X from birth to date.
* For each medical condition (death / injuries / harm) reported or identified please state all possible causes leading to such a condition and whether the condition(s) note can be said to have resulted from any particular cause and if so why it should be considered as a cause.
* Please state your views as to the likelihood of each possibility being the cause of the relevant condition / death / injury / harm and the reasons why they include or reject it as a reasonable (as opposed to a fanciful or merely theoretical) possible cause.
* Compare the likelihood of the cause (or causes) identified as reasonable possibilities being the actual cause of the relevant condition / death / injuries / harm.
* State whether you consider that a cause (or causes) is (are) the most likely cause (or causes) of the relevant death / injuries / harm and your reasons for that view.
* State whether you consider that a cause (or causes) is (are) more likely than not to be the cause (or causes) of the relevant condition / death / injuries / harm.
# Describe the child’s (current) health and development, functioning or difficulties and the prognosis for these difficulties if they are not addressed.
# Describe the child’s presenting condition / injuries, if any.
# Can you comment on the likely explanation and/ or aetiology of the child’s problems / difficulties / injuries and on the existence or likelihood of significant harm?
# Can you describe and prioritise the child’s needs, including the nature of future care-giving and treatment, in the light of the above, in the short and long term?
# Can you advise as to the parents’ / caregivers’ ability to fulfil the child’s identified needs?
# What, if anything, would be required to assist the parents / primary caregivers to be able to do so; and, if assistance is needed, what is the prognosis and timescale for change?
# Are other assessments needed?
# What are the alternative possibilities for meeting the child’s needs and what are the implications of each?
What effect will the medical condition have on the child's development and behaviour [and on his future needs]?
What level and type of care will the child need in future?
Can you comment on the likely cause, timing and mechanism of any injuries suffered by the child?
If you consider that a possible cause of X's presentation has to be ruled out, please explain why.
Is there anything of particular relevance arising from the detailed medical records?
What further investigations, if any, would need to be carried out to determine which of the possibilities put forward is correct?
Is an opthalmological [or other specfic] investigation required?
Is it possible to state whether there is any common medical predisposition or condition in this family which may be relevant to the question of causation of any injury?
Can you comment on the significance, if any, of the absence or presence of any markings on the child's body such as bruising?
Is it possible to comment on the likely presentation of the child after suffering the earlier subdural haematoma?
What significance, if any, should be attached [to the blood test results and in particular the haemoglobin level and the white blood cell count / the child's clinical presentation etc]?
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