--- name: ime-report-summary title: IME Report Critical Analysis description: 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 rebuttal strategy in personal injury litigation. author: CaseMark author_url: https://github.com/CaseMark/skills/tree/main/skills/legal/ime-report-summary 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 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. ## Prerequisites 1. **IME report** — complete defense medical expert report 2. **Treating physician records** — notes, diagnoses, treatment plans 3. **Diagnostic imaging** — MRI, CT, X-ray results 4. **Therapy records** — PT, OT, pain management documentation 5. **Prior medical exams** — pre-incident or subsequent examinations (if any) ## Workflow ### Step 1 — Examination Overview 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 | ### Step 2 — Examinee Profile Summarize: demographics, injury mechanism, current symptoms, treatment timeline, legal context. ### Step 3 — Records Review Audit - List every document the IME examiner claims to have reviewed. - Compare against the complete medical file. - **Flag all omitted records** — missing records ground a challenge for incomplete analysis. ### Step 4 — History Discrepancy Analysis 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. ### Step 5 — Comparative Medical Analysis 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]. ### Step 6 — Bias & Impeachment Indicators Check each that applies: - [ ] Minimizes subjective complaints without objective basis - [ ] Selectively cites records favoring defense; ignores contrary evidence - [ ] Uses outdated or non-standard diagnostic criteria - [ ] Offers causation opinions outside examiner's specialty - [ ] Conclusions not supported by exam findings - [ ] Cursory examination relative to injury complexity - [ ] Litigation history skews heavily defense-side - [ ] Substantial income from IME work vs. patient care - [ ] Financial relationship with referring party or insurer - [ ] Disciplinary history or criticized methodology ### Step 7 — Strategic Recommendations **Top 3–5 cross-examination vulnerabilities**, each with: - The specific weakness - Contradicting documentary evidence or medical authority - Suggested deposition/trial questions **Next steps:** - Supplemental expert consultation needed - Additional medical evidence to obtain - Rebuttal report strategy **Case impact:** Note settlement leverage if IME undermines defense, or rehabilitation steps if IME presents challenges. ## Pitfalls & Checks - Use **direct quotes** from both IME and treating records to demonstrate contradictions. - Every factual assertion must cite a specific document and page/section. - Do not editorialize — let discrepancies speak; frame analysis for attorney use. - Note jurisdiction-specific IME admissibility rules and Daubert/Frye challenge opportunities. - Maintain professional tone suitable for attorney work product.