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Writing
and Defending Your IME Report: The Comprehensive Guide
Steve Babitsky, Esquire, James J.
Mangraviti, Jr., Esquire & J. Mark Melhorn, MD
Hardbound, 645 pages
2004, SEAK,
Inc.
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Sample
section
Table
of contents
Physicians who perform IMEs, write IME reports,
and defend them at depositions, hearings, or trials now have a
new, customized, invaluable resource - the text Writing and
Defending Your IME Report: The Comprehensive Guide.
The text provides physicians with everything
they need to write better and more defensible IME reports.
In addition, it teaches physicians how to defend their IME reports.
Writing and Defending Your IME Report:
The Comprehensive Guide includes:
10 Detailed
Model Reports
27 Trick and Difficult Cross-Examination Questions (each with
three different replies and a valuable lesson spelling out what
counsel is trying to achieve and the strengths and weaknesses
of each reply
25 Tactics (fair and unfair) that opposing counsel will use to
discredit the IME physician and her report. Each one of
the 25 tactics has:
-
An explanation
of the wording in the IME report,
-
A sample
cross-examination demonstrating the tactic in action,
-
A
comment analyzing the tactic and offering specific advice
on how to defeat the tactic, and
-
An
example how to defend the IME report as written.
15 Common substantive, grammatical, typographical, and other transcription
errors with suggestions on how to catch them before your report
is finalized and how to answer questions about the mistakes that
slip through
6 Techniques for reducing the risks of being accused that the
client improperly influenced you and your IME report
35 Red Flag Words (terms) to avoid when you write your IME report
6 Techniques for avoiding the use of extraneous language and information
in your IME report. These techniques are demonstrated in
24 examples each which contain the offending language in the reports,
resulting cross-examination, comment, and defense of the report
as written
21 Techniques for making your report powerful, persuasive, and
understandable with 65 detailed examples
20 Techniques for stating your opinions and conclusions in a defensible
manner with 78 detailed examples
8 Techniques for using citations in your IME report to your advantage
with detailed examples
14 Techniques for documenting a detailed physical examination
with detailed examples
7 Techniques for obtaining and documenting a detailed, well-written,
accurate history in your IME report with detailed examples
10 Techniques for properly disclosing all documents reviewed prior
to drafting the IME report with detailed examples
6 Techniques for properly formatting your IME report with detailed
examples
5 Techniques for staying within your true are of expertise with
detailed examples
5 Techniques for accurately and objectively stating your qualifications
with detailed examples
5 Techniques for dealing with background information and transmitting
letters with detailed examples
17 Page Executive Summary providing the physician reader with
a detailed roadmap of the text
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