casemark/ime-report-summary
skills/legal/ime-report-summary/SKILL.md
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.
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SKILL.md
- name:
- ime-report-summary
- language:
- en
- 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.
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
- IME report — complete defense medical expert report
- Treating physician records — notes, diagnoses, treatment plans
- Diagnostic imaging — MRI, CT, X-ray results
- Therapy records — PT, OT, pain management documentation
- 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.
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