--- name: ime-report-analysis title: IME Report Critical Analysis description: 'Analyzes defense Independent Medical Examination (IME) reports for personal injury litigation, producing a plaintiff-side strategic memorandum with findings summary, treating-physician comparison, bias indicators, and cross-examination roadmap. Use when reviewing defense IME reports during discovery or pre-trial, preparing to depose or cross-examine a defense medical expert, or evaluating IME impact on case valuation. Trigger keywords: IME, independent medical examination, defense expert, medical examination report, cross-examination, bias indicators, impairment rating.' author: CaseMark author_url: https://github.com/CaseMark/skills/tree/main/skills/legal/ime-report-analysis license: Apache-2.0 version: 0.1.0 execution_mode: open jurisdiction: us practice: personal-injury language: en tags: [analysis, litigation, summarization, summary] --- # IME Report Critical Analysis Produces a plaintiff-side memorandum dissecting a defense IME report: findings summary, treating-physician comparison, bias indicators, and cross-examination priorities. ## Prerequisites 1. **IME report** — complete defense expert report (PDF or text) 2. **Treating physician records** — office notes, operative reports, discharge summaries 3. **Diagnostic records** — imaging (MRI, X-ray, CT), EMG/NCS, lab results 4. **Therapy records** — PT, OT, chiropractic notes with functional progress 5. **Prior medical records** — pre-incident history relevant to claimed injuries ## Output Structure ### 1. IME Report Header | Field | Detail | |---|---| | Examiner name & credentials | | | Referring party (defense counsel / carrier) | | | Examination date & location | | | Questions posed to examiner | | | Records examiner claims to have reviewed | | ### 2. Records Gap Analysis - List every record the examiner reviewed - Cross-reference against the complete medical file - **Flag omissions** — records not reviewed are a primary bias indicator ### 3. Examinee Profile - Demographics, incident mechanism, chief complaints at IME - Treatment timeline and providers - Functional limitations: treating doctor notes vs. IME history section ### 4. IME Findings Summary Summarize the examiner's opinions on: - Diagnoses and causation - MMI determination - Permanent impairment rating (note AMA Guides edition — 5th vs. 6th produces materially different ratings) - Future care recommendations - Work restrictions / disability ### 5. Treating Physician Comparison | Issue | IME Opinion | Treating Physician(s) | Source | |---|---|---|---| | Primary diagnosis | | | | | Causation | | | | | MMI status | | | | | Impairment rating | | | | | Future medical needs | | | | | Work restrictions | | | | Flag every divergence. Extract direct quotes for contradictions. ### 6. Bias & Impeachment Indicators Check each applicable red flag: - [ ] Minimizes subjective complaints without objective basis - [ ] Selectively cites records favoring defense; ignores contrary evidence - [ ] Uses outdated or non-standard diagnostic criteria - [ ] Causation opinions exceed examiner's stated specialty - [ ] Examination cursory relative to treating exam scope - [ ] IME history contradicts treating notes on same complaints - [ ] Substantial income from defense medical-legal work - [ ] High defense-to-plaintiff testimony ratio - [ ] Disciplinary actions or published methodology criticisms - [ ] Financial or referral relationship with referring carrier ### 7. Medical Authority Analysis Where IME deviates from treating physicians, cite: - AMA Guides to the Evaluation of Permanent Impairment (note edition) - Specialty-specific guidelines (AAOS, AAN, ACOEM) - Peer-reviewed literature contradicting examiner's methodology Mark unverified citations as `[VERIFY]`. ### 8. Cross-Examination Priorities Identify **3–5 highest-value vulnerabilities**: | Vulnerability | Supporting Evidence | Suggested Question Areas | |---|---|---| | | | | Focus on: - Record omissions the examiner cannot explain - Internal inconsistencies (exam findings ≠ written conclusions) - Opinions lacking foundation in the examination itself - Credential or specialty gaps for opinions rendered ### 9. Strategic Recommendations - **Rebuttal experts** — specialties needed to counter IME opinions - **Supplemental discovery** — prior testimony, financial disclosure, examiner publications - **Case valuation impact** — whether IME materially shifts settlement leverage - **Motion practice** — Daubert/Frye challenge grounds if methodology is non-standard ## Guidelines - Cite page/paragraph references from IME and medical records for every assertion - Do not characterize examiner as biased without documentary support — let the record speak - Flag jurisdiction-specific IME rules (scope and obligations vary between state tort and workers' comp) - Note whether IME was under a compulsory exam order with scope limitations - Label output as attorney work product