The exact mirror of IME Deconstruction — for defense teams. When a plaintiff discloses a medical expert, this delivers the same analytical deconstruction: unsupported assertions, omitted contrary evidence, selective guideline citation, and deposition questions calibrated to the report's specific weaknesses.
Plain-English summary of the plaintiff expert's opinions and reasoning structure.
Conclusions not supported by the cited medical evidence or treating record.
Material findings in the record that contradict the expert's opinions — not addressed in the report.
Where the expert's own cited evidence contradicts stated conclusions.
Guidelines cited out of context, partially quoted, or applied to non-matching clinical scenarios.
Where confidence levels exceed what the evidence supports — "to a reasonable degree of medical certainty" without adequate basis.
Does the expert's analytical approach meet Daubert reliability standards?
Specific vulnerabilities for Daubert motion or in limine argument.
Physician-authored deposition questions calibrated to the report's specific weaknesses.
Key points for your defense expert to address in their responsive report.
Institutional invoice terms: Net 15 or Net 30.