When your client is preparing to for the examination procedure, there are a few tips which will help to make their examination more successful:

1. The Examination Begins Immediately. Let your clients know that the examination begins as soon as you client enters the reception room. Remember, the staff is watching their every move. As soon as they walk in the door until they have left the doctors parking lot your client should assume they are being watched.
   
   
2. The Defense Doctor is NOT on your side. Even though the doctor seems nice, he is not there as your clients advocate and will testify against them when called upon to do so.
   
   
3. DO NOT allow your client to fill out any paperwork. The filling out of any materials that could potentially be used against your client is a violation of your clients right not to create potential evidence against them. Make sure that your client knows that when answering questions, he or she should BE BRIEF.
   
   
4. If your client is permitted to answer history questions, have them answer only questions which are asked directly by the examiner.
   
   
5. Regarding your Response Pleading, make sure to go over it with your client. Instruct them how you Expect that they answer history questions.
   
   If there are specific items in history that you do not want answered, instruct your client to say “my attorney advised me not to discuss that information with you as it is available to you in my medical records.”
   
   Often times, the defenses Expert will examine your client and not instruct them to indicate when a procedure produces a positive response. They will then write down that the procedure elicited no response or was negative. Your client should be instructed to speak up during the examination if a procedure is painful. They should also describe the area of pain felt for the audio recording.