Exposing Deceptive Defense Doctors

ebook Volume 2 · Exposing Deceptive Defense Doctors (7)

By Dorothy Clay Sims

cover image of Exposing Deceptive Defense Doctors

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The new edition of Exposing Deceptive Defense Doctors overflows with new text, practice tips, strategic advice, and forms. The highlights include new or expanded coverage of a broad range of topics, including:

What to Do Before and After the Defense Medical Exam

  • 9 arguments you can make to persuade the defense (and, if necessary, the court) to allow a videographer to observe/tape the exam

    What to Do Before, During, and After the Deposition

  • How to take a bad deposition every time
  • A better approach – how to take a good deposition every time

    Psychological Tests

  • To protocol or not to protocol
  • Sample cross-exam re: misuse of norms that include race

    8 commonly administered psychological tests, including a description of the test; how bad DMEs will try to manipulate it; and how to respond to/challenge the DME:

  • Montreal Cognitive Assessment (MoCA)
  • Sentence Completion Test
  • State-Trait Anxiety Inventory for Adults
  • Stroop
  • Trauma Symptom Inventory (TSI), 2
  • CAPS-5
  • Neuropsychological Assessment Battery (NAB)
  • Conners' Continuous Performance Test, III

    Debunking Claims of Exaggeration and Malingering

  • 15 commonly administered malingering "tests," including a description of the test; how bad DMEs will try to manipulate it; and how to respond/challenge the DME:

  • MMPI-2-RF (4 different scales explained and analyzed)
  • Dot Counting Test
  • Pain Scales (8 different scales explained and analyzed)
  • Structured Inventory of Malingered Symptomatology (SIMS)
  • Oswestry Disability Scales

    Cross-Examination and Traumatic Brain Injury

  • Checklist of areas the DME could/should test for in diagnosing TBI
  • How to paint a "before and after" picture to challenge the DME's claim that your client will be "just fine."

    Cross-Examination and Pain

  • How to use brain scans to prove pain
  • Another practical tip for challenging the DME's claim that your client should be pain-free by now

    Technology, Outsourcing and Cross-Examination in the Practice of Law

  • A cautionary note about facial recognition software
  • How to use Fitbit and/or sleep apps on your phone to your client's advantage

    New Forms and Appendices

  • Form: Arrangement of Hospital Chart (Omissions Checklist)
  • Form: Authorization to Release Membership Information
  • Form: Stipulation re Conditions of Psychological Examination
  • Forms: Collection of court orders allowing expert testimony re the use of DTI
  • Appendix: Airbags — What Every Lawyer Needs to Know
  • Appendix: Challenging a Coding "Expert" (includes a practice-tested motion in limine)
  • Exposing Deceptive Defense Doctors