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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)