IME Preparation Checklist

IME PREPARATION CHECKLIST

Comprehensive Preparation Guide for Independent Medical Examination

CLIENT INFORMATION

Client Name: [________________________________]

File Number: [________________________________]

IME Date: [________________________________]

IME Time: [________________________________]

Examiner: [________________________________]

Examiner Specialty: [________________________________]

Location: [________________________________]

Requesting Party: [________________________________]

Defense Counsel: [________________________________]

PART 1: PRE-IME ATTORNEY/PARALEGAL TASKS

1.1 IME Notice Review

☐ Date IME notice received: [________________]
☐ Timely served: ☐ Yes ☐ No
☐ Examiner designated: [________________]
☐ Body parts/conditions to be examined: [________________]
☐ Records examiner will review: [________________]
☐ Objections deadline: [________________]

1.2 Examiner Research

☐ Examiner's background researched
☐ Board certifications verified
☐ Publications reviewed
☐ Prior testimony researched (verdicts/depositions)
☐ Known defense orientation documented
☐ Previous reports obtained (if available)
☐ Bias indicators identified

Examiner Notes:
[________________________________]
[________________________________]
[________________________________]

1.3 Objections Considered

☐ Objections to examiner evaluated
☐ Objections to scope evaluated
☐ Recording rights researched for jurisdiction
☐ Observer rights researched for jurisdiction
☐ Response/objection letter sent: [________________]
☐ Conditions confirmed by defense counsel

1.4 Records Provided to Examiner

☐ Listed all records sent by defense to examiner
☐ Verified records are accurate and complete
☐ Noted any concerning records examiner will review
☐ Identified gaps in records

Records examiner will have:
| Source | Dates | Pages | Concerns |
|--------|-------|-------|----------|
| [________] | [________] | [____] | [________] |
| [________] | [________] | [____] | [________] |
| [________] | [________] | [____] | [________] |

1.5 Client's Medical History Review

☐ Reviewed all treating physician records
☐ Reviewed all diagnostic test results
☐ Created timeline of treatment
☐ Identified all diagnoses
☐ Identified pre-existing conditions
☐ Noted any inconsistencies in records
☐ Prepared summary for client review

PART 2: CLIENT MEETING - PREPARATION SESSION

Meeting Date: [________________________________]

Meeting Duration: [________________________________]

Attendees: [________________________________]

2.1 Explain the IME Process

☐ Explained what an IME is and its purpose
☐ Explained that examiner is hired by defense
☐ Explained examiner is not there to treat client
☐ Explained importance of being truthful but careful
☐ Explained how IME report may be used
☐ Explained right to record (if applicable in jurisdiction)
☐ Explained right to observer (if applicable in jurisdiction)

2.2 Review Medical History with Client

☐ Reviewed mechanism of injury
☐ Reviewed all injuries claimed
☐ Reviewed all symptoms (current and past)
☐ Reviewed all treatment received
☐ Reviewed current treatment plan
☐ Reviewed medications
☐ Reviewed functional limitations
☐ Reviewed work status/restrictions
☐ Reviewed activities of daily living impact
☐ Discussed pre-existing conditions

2.3 Potential Problem Areas Identified

☐ Inconsistencies in records reviewed with client
☐ Gaps in treatment explained
☐ Prior injuries discussed
☐ Social media concerns addressed
☐ Surveillance concerns addressed
☐ Any exaggeration/minimization concerns addressed

Problem areas noted:
[________________________________]
[________________________________]
[________________________________]

2.4 Examiner Background Shared

☐ Shared examiner's name and specialty
☐ Shared examiner's reputation (if known)
☐ Shared examiner's typical findings (if known)
☐ Prepared client for possible examiner demeanor

2.5 Key Points to Remember

Discussed with client:

☐ Be truthful - never exaggerate or minimize
☐ Be polite and cooperative
☐ Answer questions directly
☐ Don't volunteer information
☐ Describe symptoms on average day
☐ Describe both good days and bad days
☐ Tell examiner when something hurts
☐ Don't perform activities causing severe pain
☐ Be consistent with treating physician statements
☐ Pay attention to examination details
☐ Note start/end times

PART 3: PRACTICE QUESTIONS

3.1 Common IME Questions to Review

Practice answering the following types of questions:

Accident/Incident Questions:
☐ "Tell me about the accident."
☐ "What happened?"
☐ "Where were you hit?"
☐ "Were you wearing a seatbelt?"
☐ "Did airbags deploy?"
☐ "What did you do immediately after?"

Symptom Questions:
☐ "Where does it hurt?"
☐ "Rate your pain on a scale of 1-10."
☐ "What makes it better? Worse?"
☐ "How often do you have symptoms?"
☐ "What can't you do that you used to do?"
☐ "How do you spend a typical day?"

Treatment Questions:
☐ "Who are your doctors?"
☐ "What treatment have you received?"
☐ "What medications do you take?"
☐ "Has treatment helped?"
☐ "Are you still treating?"

Work Questions:
☐ "What is your job?"
☐ "Have you missed work?"
☐ "Can you do your job now?"
☐ "Do you have any restrictions?"

Pre-Existing Condition Questions:
☐ "Have you ever had problems with [body part] before?"
☐ "Have you ever been in an accident before?"
☐ "Have you ever seen a doctor for [condition] before?"
☐ "Have you ever had any surgeries?"

3.2 Client's Answers Reviewed

☐ Client's answers to practice questions reviewed
☐ Inaccuracies corrected
☐ Inconsistencies addressed
☐ Client understands how to answer appropriately

PART 4: LOGISTICS

4.1 Location and Transportation

☐ IME location confirmed: [________________________________]
☐ Directions provided to client
☐ Parking instructions provided
☐ Estimated travel time: [________________]
☐ Transportation arranged: ☐ Client driving ☐ Family member ☐ Rideshare ☐ Other

4.2 What to Bring

Instructed client to bring:

☐ Photo ID
☐ Insurance cards
☐ List of medications with dosages
☐ List of treating physicians
☐ Any assistive devices used (brace, cane, etc.)
☐ Preparation materials from attorney
☐ Recording device (if permitted)
☐ Observer (if permitted)
☐ Questions for examiner (if any)

4.3 What NOT to Bring

Instructed client NOT to bring:

☐ Medical records (already provided by attorneys)
☐ X-rays or imaging (already provided)
☐ Settlement demands or legal documents
☐ Anything not discussed with attorney

4.4 Recording/Observer Arrangements

☐ Recording permitted in jurisdiction: ☐ Yes ☐ No
☐ Recording device arranged: ☐ Audio ☐ Video
☐ Observer permitted: ☐ Yes ☐ No
☐ Observer arranged: [Name: ________________]
☐ Observer instructions provided

PART 5: DAY OF IME REMINDERS

5.1 Before Leaving Home

☐ Get adequate sleep night before
☐ Eat normally
☐ Take regular medications
☐ Wear comfortable clothing
☐ Wear clothing that allows examination of injured areas
☐ Allow extra time for travel
☐ Bring items listed above

5.2 At the IME

☐ Arrive 15 minutes early
☐ Note arrival time
☐ Complete any paperwork carefully
☐ Do not sign anything without understanding it
☐ Note examination start time
☐ Be polite and cooperative
☐ Answer questions truthfully
☐ Describe symptoms accurately
☐ Report pain during examination
☐ Ask to stop if needed
☐ Note examination end time

5.3 After the IME

☐ Note end time immediately
☐ Write down everything remembered
☐ Call attorney's office to report
☐ Complete post-IME questionnaire

PART 6: CLIENT ACKNOWLEDGMENT

I, [CLIENT NAME], acknowledge that I have:

☐ Met with my attorney/legal team to prepare for the IME

☐ Reviewed my medical history and treatment

☐ Practiced answering typical IME questions

☐ Received and reviewed written preparation materials

☐ Understand what to expect at the IME

☐ Understand my rights regarding recording/observation

☐ Understand the importance of being truthful

☐ Know what to bring and what not to bring

☐ Have transportation arranged

☐ Know to contact my attorney after the IME

☐ Have my attorney's contact information

Attorney Contact: [________________________________]

Phone: [________________________________]

Emergency Contact: [________________________________]

Client Signature: _________________________________ Date: ______________

Attorney/Paralegal Signature: _________________________________ Date: ______________

PART 7: POST-IME DEBRIEFING

Debriefing Date: [________________________________]

Debriefing Method: ☐ In-person ☐ Phone ☐ Video

7.1 IME Summary

Examination Duration: [________________] minutes

History Taking Duration: [________________] minutes

Physical Exam Duration: [________________] minutes

Examiner's Demeanor: ☐ Neutral ☐ Friendly ☐ Hostile ☐ Rushed ☐ Thorough

7.2 Questions Asked

☐ Documented all history questions asked
☐ Documented client's answers
☐ Identified any concerning questions
☐ Identified any leading questions

7.3 Physical Examination

☐ Documented all body parts examined
☐ Documented all tests performed
☐ Documented client's pain responses
☐ Noted if examination seemed adequate
☐ Noted if examination seemed limited

7.4 Concerns Identified

☐ Any problems during examination
☐ Any concerning comments by examiner
☐ Any areas where client may have misspoken
☐ Any tests not performed that should have been

7.5 Recording Review (if applicable)

☐ Recording reviewed
☐ Notes made from recording
☐ Concerning statements identified
☐ Contradictions with medical records noted

PART 8: IME REPORT ANALYSIS

Report Received Date: [________________________________]

8.1 Report Review Checklist

☐ History section accurate
☐ Examination findings documented
☐ All body parts examined noted
☐ All tests performed noted
☐ Diagnoses stated
☐ Causation opinion provided
☐ Treatment recommendations (if any)
☐ Work status opinion (if any)
☐ Permanency opinion (if any)
☐ MMI opinion (if any)

8.2 Inaccuracies Identified

8.3 Rebuttal Strategy

☐ Treating physician rebuttal needed
☐ Additional expert needed
☐ Cross-examination outline prepared
☐ Examiner's bias documented
☐ Prior contradictory testimony identified