In this particular case, I have no clue!
Originally, I supposed that a death certificate would NOT have been issued until removal of the ventilator, and the ME/ Coroner taking custody of her body.
But with all the issues in this case, I have no idea. I am confident that her medical records amply reflect that she has been examined and found to be brain dead "multiple" times, by multiple providers (around 6, IIRC).
I agree with joypath and others that the judge really defined "independent" in a way that is puzzling, and I can only wonder if something was revealed in chambers that caused him to redefine "independent". I don't think the court was questioning the findings of the 3 docs, just the definition as to whether the original #2 doc was "sufficiently" independent. That is vastly different from insinuating that the hospital recklessly did something non-standard or incompetent, or illegal, or even malicious, in the brain death determination, as has been alleged here in a few posts.
I'm wondering if one of the "independent" docs was found to have contact with Jahi, for example, while on call, and wrote orders on her before she was considered for brain death, and this was determined in chambers discussions. The judge was extra conservative, and I don't have a problem with that. Dr. Fisher's evaluation was pretty definitive, and his CV is impeccable, and there is no question he is independent. Just my speculation about why the judge would sort of redefine "independent".
But it is definitely not "standard of care" to bring in docs from outside the hospital to examine for brain death, just to be considered independent. In my experience, "independent" is defined in policy to mean that they were not substantially involved with the patient's care, as an attending. I've never heard anything that the "independent" doc could not have "any" contact with the patient. Independent also means they conduct their OWN examination, and not just review the notes of another. That does not mean that a whole new PET/ CT scan has to be done-- they can review the films themselves, just not rely on someone else's interpretation.