It is very difficult for an attorney to cross-examine a “seasoned” defense doctor at arbitration or trial for two reasons. First, at arbitration, the defense attorney just submits only the defense medical report with the defense doctor not being present to cross-examine. Secondly, whether at trial or arbitration, if the plaintiff's attorney or his/her clerk appears at the Defense Medical Exam with the plaintiff, he or she is not qualified to testify which tests were performed improperly by the defense doctor and which tests were completely omitted. Should you decide to have the treating doctor present with your client, his/her testimony will be looked on as “biased” in order to protect his medical services and fees.

Remember, the conclusion rendered by the defense doctor is only as strong as the facts or lack thereof which support it. Rather than simply attack the credibility of the defense doctor on the grounds that he/she performed a short examination or that he “makes a living” out of testifying for the defense, you can further and more convincingly discredit him/her by arguing that the Defense Doctor's

simply because the examination tests were performed improperly and/or there were examination omissions.

We at PRIME provide you with a medical observer who will be present at the examination and write a report concerning the results. Our doctors will also protect your client by precluding any and all tests that you do not wish to be performed or any questions you do not want your client to answer. In addition, our doctors will review and compare the medical report written by the defense doctor and help you focus on the important medical issues.