Notice of Taking Deposition of Corporation Regarding Driver Employee


SKU: DF-BI-3010

“When the defense counsel asks for an IME of your client, give your plaintiff client some advice. Make them an effective witness to the adverse doctor. Gain something – don't lose something with an IME!”

Most attorneys do not prepare their personal injury clients for the defense medical examination. 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. Failure to advise your personal injury client to be an effective witness to the adverse doctor can lead to problems you could have avoided.

Why don’t most attorneys give such needed advice to their client?

  • Because they don’t want to take the hours of time needed to construct a great instructions handout for the client; or
  • they don’t want to talk to the client for another hour.

That does not have to be you!

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, just for your own mental practice at home, of the ways in which the accident has affected your everyday life. Do not take the list to the medical examination. Leave the list at home. But write it out as practice so you know you can think of everything when you are asked!

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 doctor more impressed with the injury than you expected.

That’s a sample. In short, this Client Handout for IME is loaded with solid advice; it will not take your 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).

We are selling the Client Handout for IME for only $16.95. Click the “Add to cart” button.

All The Best,
Leonard H. Bucklin
Leonard Bucklin
Civil Trial Attorney


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