"Before the defense medical exam of your bodily injury (BI) plaintiff, give your client sound advice to study at home - so they do not make mistakes that hurt their case. Make your client an effective witness to the adverse doctor."
Use our form handout --- a legal form handout for an attorney to give his/her client facing an adverse medical exam. Without time on your part, your client with have a handout of advice packed with good tips, such as:
"The defense doctor will ask you how the injury has affected you. Be prepared to make a full answer. We know of instances where a person has just said a few items and the defense doctor reports (and tells the jury): "The patient denied any other effect from the injury except...." Therefore, write out now another list, for your own mental practice, of the ways in which the accident has affected your everyday life.
You will not be considered brave or modest if you do not tell everything that the injury did to you. Anything you leave out, the defense doctor will say you "denied" to him that you had the problem!"
Give your client advice like that and your client can testify in court "I told the defense doctor that ....." and defense doctor has to testify on cross-examination that he/she was told "that ....". You wind up with a defense doctor refreshing the jury with the injury facts. And probably you will wind up with a defense doctor more impressed with the plaintiff's injury than you expected.
That's a sample. In short, this Client Handout for IME is loaded with solid advice; it will not take you time to construct, and it will not take you time to talk it all out with the client. You can just hit the high points with the client (or a good legal assistant can use the form with your client).
As we all know, the defense medical exam is not an "independent" medical exam. It is an exam by a doctor who usually is an advocate for the defense cause. It is an "adverse" examination, with adverse questioning. Clients should have advice to prepare them for the questions they will get from a defense advocate doctor.
Why don't most attorneys give needed advice to the client?
Because they don't take the hours of time needed to construct a great letter of instructions or handout for the client.
That does not have to be you! With no time investment on your part, you will be preparing clients the right way.
We are selling the Client Handout for IME for only $16.95! Use the "Buy Now" button. For this price, plus a money-back guarantee, you cannot lose.
All The Best,
Leonard Bucklin, Civil Trial Attorney
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