ime-report-summary
Critically analyzes defense IME reports by auditing record completeness, comparing findings against treating physician records, and surfacing bias indicators and cross-examination vulnerabilities. Triggers when reviewing an IME report, preparing for defense expert deposition, or building a rebutt...
Full skill instructions
Produce a plaintiff-side critical analysis memorandum of a defense IME report. The output is usable for cross-examination outlines, expert witness preparation, and admissibility motions.
Populate this table from the IME report:
| Field | Detail |
|---|---|
| Examiner | Name, credentials, specialty |
| Referral source | Defense counsel / insurance carrier |
| Date & location | When and where conducted |
| Questions posed | Specific issues examiner addressed |
| Scope limitations | Records not reviewed, tests not performed |
Summarize: demographics, injury mechanism, current symptoms, treatment timeline, legal context.
Compare the IME's recitation of patient history against treating records:
| Issue | IME States | Treating Records Show | Significance |
|---|---|---|---|
| Symptom onset | |||
| Complaint severity | |||
| Functional limitations | |||
| Treatment response |
Flag symptoms minimized or absent from the IME that appear in treating notes, and physical exam findings conflicting with contemporaneous treating exams.
Side-by-side comparison on each contested issue:
| Issue | IME Opinion | Treating Physician Opinion | Supporting Authority |
|---|---|---|---|
| Causation | |||
| MMI status | |||
| Permanent impairment rating | |||
| Future care needs | |||
| Work restrictions / disability |
Cite AMA Guides, specialty clinical guidelines, and peer-reviewed literature. Mark uncertain citations with [VERIFY].
Check each that applies:
Top 3–5 cross-examination vulnerabilities, each with:
Next steps:
Case impact: Note settlement leverage if IME undermines defense, or rehabilitation steps if IME presents challenges.
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