Registered Nurse to accompany your Personal Injury Plaintiff

Why sending this Registered Nurse to act as observer during your plaintiff’s independent medical examination bolsters your personal injury litigation:

As you are aware, a great many doctors who perform Independent Medical Examinations in personal injury litigation are influenced by the fact that they are being paid by the defense, and perceive that the client who pays their bill expects the defense position to be improved as a consequence of the IME report. Accordingly, many IME doctors appear to skew their report on the plaintiff in favor of the defense. A subset of IME doctors have a very poor reputation for fairness or accuracy, and will present whatever medical opinion the defense attorney desires. Once the IME doctor has prepared a report which unfairly depicts the plaintiff’s examination, there is little that can be done to refute this—unless you have had this Registered Nurse observer attend. The reality is, that when I politely stand present with my audio recorder turned on, dangling from my neck, while taking notes—the physician will then most likely produce a more objective report.

Those plaintiffs I have attended independent medical examinations with, have overwhelmingly communicated that having me there made them feel much more comfortable during the physician’s exam. I meet the client at least fifteen minutes prior to the time of the doctor’s appointment, identify myself as a registered nurse, and do my best to put them at ease. I review that their attorney has sent me to be his representative in attending and observing the doctor’s examination, I will be audio recording the office visit, also will be taking written notes, and the fact that the opposition in the lawsuit is paying the doctor to perform the examination. I briefly discuss that the opposition’s case would be improved if the doctor’s report finds a lesser injury, or a more full recovery. The client is cautioned not to assume that the doctor is watching their face for expressions of pain and encouraged to inform the doctor out loud if any part of the examination hurts or is uncomfortable--with these words then being recorded. I reassure the client not to worry--that I’ll be there with them during the entire examination. I also review any Response to Demand that the attorney may have provided. My notes, which are attorney work product pertinent to the plaintiff’s representation, may include, but are not limited to the following:

Time examination began, key events, narrative and time it concluded.
Examiner’s questions and client’s answers.
Diagnostic tests and results of these.
Verbal and nonverbal indications of pain or discomfort during the examination.
Persons present during the examination and any function they may have performed.
Assistive aids, gait disturbances, or other physical deficits noted in the client.

I’ve attended many IMEs, so producing the typewritten report of the examination takes minimal time and I attach a copy of the physician’s card which I obtain from the office. I submit my report and the audio recording CD to the attorney expeditiously. I include the suggestion that I, or someone from the attorney’s office, compare my notes against the text of the physician’s report when it is made available. I am, of course, available as witness in support of my documentation as well as the audio recording of the examination, if there appears to be important inconsistencies noted in the doctor’s report.

Contact us now to schedule attendance at your client's IME anywhere in Los Angeles County, Orange County, and throughout Southern California

Michael Haiby, RN

Phone: (661) 252-3435
Cell: (661) 414-6972
Email: LNCassist@aol.com
www.independent-medical-examination.com

Michael Haiby, RN provides the service of independent medical examination nurse observer to plaintiff attorneys. Plaintiff individuals may ask the attorney's office to make contact for more information on IME nurse observer services-- only an attorney can give legal advice.