Methods and apparatus for selectively applying electrical energy to a
target location within a patient's body, particularly including tissue in
the spine. In a method of the invention high frequency (RF) electrical
energy is applied to one or more active electrodes on an electrosurgical
probe in the presence of an electrically conductive fluid to remove,
contract or otherwise modify the structure of tissue targeted for
treatment. In one aspect, a dura mater and spinal cord are insulated from
the electrical energy by an insulator positioned on a non-active side of
the probe. In another aspect, a plasma is aggressively formed in the
electrically conductive fluid by delivering a conductive fluid to a
distal end portion of the probe and aspirating the fluid from a location
proximal of the return electrode. In another aspect, a distal end of an
electrosurgical probe having at least one electrode on a biased, curved,
bent, or steerable shaft is guided or steered to a target site within an
intervertebral disc having a disc defect for treatment of tissue to be
treated at the target site by the selective application of electrical
energy thereto.