CHAPTER 1 DIAGNOSING THE DOCTOR
CHAPTER 2 WHAT TO DO BEFORE AND AFTER THE DEFENSE MEDICAL EXAM
CHAPTER 3 WHAT TO DO BEFORE, DURING, AND AFTER THE DEPOSITION
CHAPTER 4 CROSS-EXAMINATION AT TRIAL
CHAPTER 5 PSYCHOLOGICAL TESTS
CHAPTER 6 JUNK DEFENSES TO PSYCHIATRIC/NEUROPSYCHIATRIC CONDITIONS
CHAPTER 7 DEBUNKING CLAIMS OF EXAGGERATION AND MALINGERING
CHAPTER 8 CROSS-EXAMINATION AND DEPRESSION
CHAPTER 9 CROSS-EXAMINATION AND PTSD
CHAPTER 10 CROSS-EXAMINATION AND SOMATOFORM DISORDER
CHAPTER 11 CROSS-EXAMINATION AND TRAUMATIC BRAIN INJURY
CHAPTER 12 CROSS-EXAMINING THE PSYCHOLOGIST, NEUROPSYCHOLOGIST & PSYCHIATRIST
[CHAPTERS 13-14 RESERVED]
CHAPTER 15 CROSS-EXAMINING NEUROLOGISTS, ORTHOPEDISTS & PMR DOCTORS
CHAPTER 16 CROSS-EXAMINATION OF RADIOLOGISTS AND NEURORADIOLOGISTS
CHAPTER 17 SPINE/SOFT TISSUE/DISC INJURIES
CHAPTER 18 CROSS-EXAMINATION AND PAIN
CHAPTER 19 CROSS-EXAMINATION AND RSD/CRPS
CHAPTER 20 FUNCTIONAL CAPACITIES EVALUATION
CHAPTER 21 DEPOSING THE ERISA/LTD PHYSICIAN
CHAPTER 22 CROSS-EXAMINING CAUSATION EXPERTS
CHAPTER 23 UPPER EXTREMITY INJURIES
CHAPTER 24 LOWER EXTREMITY INJURIES
CHAPTER 25 CROSS-EXAMINING THE VOCATIONAL REHABILITATION EXPERT/LIFE-CARE PLANNER
[CHAPTER 26 RESERVED]
CHAPTER 27 TECHNOLOGY, OUTSOURCING AND CROSS-EXAMINATION IN THE PRACTICE OF LAW

The new edition of Exposing Deceptive Defense Doctors overflows with new text, practice tips, strategic advice, and forms. The highlights include new or expanded coverage of a broad range of topics, including:

What to Do Before and After the Defense Medical Exam

• 9 arguments you can make to persuade the defense (and, if necessary, the court) to allow a videographer to observe/tape the exam

What to Do Before, During, and After the Deposition

• How to take a bad deposition every time
• A better approach – how to take a good deposition every time

Psychological Tests

• To protocol or not to protocol
• Sample cross-exam re: misuse of norms that include race

8 commonly administered psychological tests, including a description of the test; how bad DMEs will try to manipulate it; and how to respond to/challenge the DME:

• Montreal Cognitive Assessment (MoCA)
• Sentence Completion Test
• State-Trait Anxiety Inventory for Adults
• Stroop
• Trauma Symptom Inventory (TSI), 2
• CAPS-5
• Neuropsychological Assessment Battery (NAB)
• Conners’ Continuous Performance Test, III

Debunking Claims of Exaggeration and Malingering

• 15 commonly administered malingering “tests,” including a description of the test; how bad DMEs will try to manipulate it; and how to respond/challenge the DME:
• MMPI-2-RF (4 different scales explained and analyzed)
• Dot Counting Test
• Pain Scales (8 different scales explained and analyzed)
• Structured Inventory of Malingered Symptomatology (SIMS)
• Oswestry Disability Scales

Cross-Examination and Traumatic Brain Injury

• Checklist of areas the DME could/should test for in diagnosing TBI
• How to paint a “before and after” picture to challenge the DME’s claim that your client will be “just fine.”

Cross-Examination and Pain

• How to use brain scans to prove pain
• Another practical tip for challenging the DME’s claim that your client should be pain-free by now

Technology, Outsourcing and Cross-Examination in the Practice of Law

• A cautionary note about facial recognition software
• How to use Fitbit and/or sleep apps on your phone to your client’s advantage

New Forms and Appendices

• Form: Arrangement of Hospital Chart (Omissions Checklist)
• Form: Authorization to Release Membership Information
• Form: Stipulation re Conditions of Psychological Examination
• Forms: Collection of court orders allowing expert testimony re the use of DTI
• Appendix: Airbags — What Every Lawyer Needs to Know
• Appendix: Challenging a Coding “Expert” (includes a practice-tested motion in limine)