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These forms are excerpted from a larger collection in Dorothy Clay Sims’ Exposing Deceptive Defense Doctors. This popular book reveals the games DMEs play and provides proven techniques, arguments, resources, and forms for making juries and neutrals angry at the misrepresentation.

Chapter 2: What to Do Before and After the Defense Medical Exam:

Form 2-2: Client Consultative Questionnaire

Form 2-4: Motion to Permit Court Reporter to Attend Psychological Examination and Testing

Form 2-7: Stipulation re: Parameters of Defense Medical Examination

Form 2-8: Plaintiff’s Objection to Defendant’s Notice of Examination; Plaintiff’s Requests for Production; Interrogatories

Chapter 3: What to Do Before, During, and After the Deposition:

Form 3-1: DME Subpoena Attachment for Records

Form 3-2: Doctor Research—Staff Checklist [Sample 1]

Form 3-3: Doctor Research—Staff Checklist [Sample 2]

Form 3-5: Attorney’s Deposition Checklist

Chapter 7: Debunking Claims of Exaggeration and Malingering:

Form 7-1: Motion to Determine Admissibility of Expert Testimony

Form 7-2: Memorandum of Law in Support of Motion in Limine re FBS

One of the forms on this list is provided in full below. The rest are two clicks away.

For immediate and free access to the forms listed above,
fill in these three blanks and press Download Forms.

Form 3-3: Doctor Research—Staff Checklist [Sample 2]

1. www.almexperts.com/ExpertWitness/experts_and_consultants/index.html

Search for the doctor’s name. This may provide a CV on the doctor.

2. www.floridamalpractice.com/linksdoctor.htm

This site is for Florida doctors only. Look for similar sites in other states.

Look up the doctors license.
Copy and paste into a word document.
Click on Practioner’s Profile, Click on Printer Friendly Version.
Copy and paste into a Word document.

3. https://apps.fldfs.com/PLCR/Search/MPLClaim.aspx

Check for malpractice claims. (This site is only for Florida doctors.)
Medical Professional Liability (MPL) Reporting Claims.
Insured (Doctor’s/Physician’s) First Name, Insured (Doctor’s/Physician’s) Last Name.
Enter first and last name.
Click on any results and copy and paste the claim into a Word document.

4. www.ama-assn.org/ama/pub/category/2645.html

This site allows you to look up other state medical licenses.

Click on the link to the state the doctor is licensed in and find on the state website the online license verification.
Search by doctor’s name.
Copy and paste the license(s) into a Word document.

5. www.nationalregister.org/links_licensingboards.htm

This site allows you to look up psychologist licenses.

Click on the link to the state the doctor is licensed in and find on the state website the online license verification.
Search by doctor’s name.
Copy and paste the license(s) into a Word document.

6. www.lexis.com

If you use this site:

Sign on.
Enter Client.
Reminder: with doctors in Florida, make sure you search the news publications in Lexis (this is easiest if you do it through the drop down menu).

SmartLinxT—Personal Summary Reports

Unclick the “Use similar sounding terms for Last Name”
Search by Last Name, First Name and State (Make sure terms and connectors is checked)
If you get more than 30 results, you may need to provide additional information, such as middle initial or city
Review the results to be sure they are the right person, look for indicators, such as middle initial, correct city, birthdate, or a medical license. (You can click on the name to see the full report.)
Click the checkboxes of the ones you want and then click download. This will pop up a new window. Choose from the drop down menu and choose Text document (TXT). Make sure that only the box that says “Each document starts on a new page” is clicked and no others.
Make sure the drop down menu is on “Full” and not “Cite.”
Click Download.
When it finishes, it will provide you with a link, right click on the link and click “save target as” then save the document wherever you wish to save it.

SmartLinxT—Business Summary Report

Search by State, Last Name and First Name (Make sure terms and connectors is checked)
Review the results to make sure they are associated with the right person (the best way is to make sure the person’s name is in the report and they are in the right city or the report contains the person’s middle initial or degree (M.D., Ph.D.))
Click the checkboxes of the ones you want and then click download. This will pop up a new window. Choose from the drop down menu and choose Text document (TXT). Make sure that only the box that says “Each document starts on a new page” is clicked and no others.
Make sure the drop down menu is on “Full” and not “Cite.”
Click Download.
When it finishes, it will provide you with a link, right click on the link and click “save target as” then save the document wherever you wish to save it.

Public Records—Combined Verdicts, Settlements and Expert Directories—Jury Verdicts and Settlements, Combined

Search by the person’s name (First Last) (Make sure terms and connectors is checked).
Review the results to make sure that each reference is to the doctor you are searching for. Look for the specialty and location of the doctor in the verdict to be sure. If the doctor is a party in the verdict, make sure it is in the right state.
Click the checkboxes of the ones you want and then click download. This will pop up a new window. Choose from the drop down menu Word document (DOC). Make sure the drop down menu is on “Full” and not “Cite.”
Make sure that “dual column” is not selected. Make sure that only the box that says “Each document starts on a new page” is clicked and no others.
Click Download.
When it finishes, it will provide you with a link, right click on the link and click “save target as” then save the document wherever you wish to save it.
Repeat the search with the middle initial and with any other combination variations of the doctor’s name.

Federal Legal—US—Federal Court Cases, Combined

Search by the person’s name (First Last) (Make sure terms and connectors is checked)
Also search for Dr. (Last)
Review the cases to make sure that each reference is to the doctor you are searching for. Look for the specialty and the location of the doctor in the case to be sure. If the doctor is a party in the case, make sure it is in the right state.
Click the checkboxes of the ones you want and then click download. This will pop up a new window. Choose from the drop down menu “Word document (DOC).” Make sure the drop down menu is on “Full” and not “Cite.”
Make sure that “dual column” is not selected. Make sure that only the box that says “Each document starts on a new page” is clicked and no others.
Click Download.
When it finishes, it will provide you with a link, right click on the link and click “save target as” then save the document wherever you wish to save it.
Repeat the search with the middle initial and with any other combination variations of the doctor’s name.
Also try “Dr ___,” although this may get you more cases then is feasible to review and is not really necessary if you have a good number of cases already. If you do this search, you must review each case to make sure it is the correct doctor and also that it is not a case you already have downloaded.

State Legal—US—Combined States—Cases—By Court—State Court Cases, Combined

Search by the person’s name (First Last) (Make sure terms and connectors is checked)
Also search for Dr. (Last)
Review the cases to make sure that each reference is to the doctor you are searching for. Look for the specialty and the location of the doctor in the case to be sure. If the doctor is a party in the case, make sure it is in the right state.
Click the checkboxes of the ones you want and then click download. This will pop up a new window. Choose from the drop down menu “Word document (DOC).” Make sure the drop down menu is on “Full” and not “Cite.”
Make sure that “dual column” is not selected. Make sure that only the box that says “Each document starts on a new page” is clicked and no others.
Click Download.
When it finishes, it will provide you with a link, right click on the link and click “save target as” then save the document wherever you wish to save it.
Repeat the search with the middle initial and with any other combination variations of the doctor’s name.
Also try “Dr ___,” although this may get you more cases than is feasible to review and is not really necessary if you have a good number of cases already. If you do this search, you must review each case to make sure it is the correct doctor and also that it is not a case you already have downloaded.

Public Records—Find a Person—Criminal History—Criminal History Records

New Search (at top of screen).
Search by the person’s name (First Last) (Make sure terms and connectors is checked).
Review the results to make sure they refer to the right person. Look to see if it is in the right state or if the person has the same middle initial.
Click the checkboxes of the ones you want and then click download. This will pop up a new window. Choose from the drop down menu Word document (DOC). Make sure the drop down menu is on “Full” and not “Cite.”
Make sure that “dual column” is not selected. Make sure that only the box that says “Each document starts on a new page” is clicked and no others.
Click Download.
When it finishes, it will provide you with a link, right click on the link and click “save target as” then save the document wherever you wish to save it.

Public Records—Find a Business—Business and Corporation Information—Combined Business and Corporation Information

New Search (at top of screen)
Search by the person’s name (First Last) (Make sure terms and connectors is checked)
Review the results to make sure they are associated with the right person (the best way is to make sure the person is in the right city or the report contains the person’s middle initial or degree (M.D., Ph.D.))
Also look for any businesses that you found when you did the Business Summary Reports earlier.
Click the checkboxes of the ones you want and then click download. This will pop up a new window. Choose from the drop down menu Word document (DOC). Make sure the drop down menu is on “Full” and not “Cite.”
Make sure that “dual column” is not selected. Make sure that only the box that says “Each document starts on a new page” is clicked and no others.
Click Download.
When it finishes, it will provide you with a link, right click on the link and click “save target as” then save the document wherever you wish to save it.

News—By Country & Region—United States (FOR DOCTORS IN FLORIDA ONLY)

Click every box (up to 18) next to all the choices and click on Combine Sources.
Search by the person’s name (First Last) (Make sure terms and connectors is checked)
Review the results to make sure they are associated with the right person (the best way is to make sure the person is in the right city/county, is called a doctor/physician, the report contains the person’s middle initial or degree (M.D., Ph.D.))
Click the checkboxes of the ones you want and then click download. This will pop up a new window. Choose from the drop down menu Word document (DOC). Make sure the drop down menu is on “Full” and not “Cite.”
Make sure that “dual column” is not selected. Make sure that only the box that says “Each document starts on a new page” is clicked and no others.
Click Download.
When it finishes, it will provide you with a link, right click on the link and click “save target as” then save the document wherever you wish to save it.
Repeat with the other 19 sources combined.
Sign Off.

7. Check county courthouse website for lawsuits/divorces doctor has been involved in.

To check what county/city the doctor lives and works in, go to www.naco.org/Template.cfm?Sectionfiltered=Data_and_Demographics&Template=/cffiles/counties/city_srch.cfm

You may be able to find the courthouse through the county’s website OR search www.google.com for the county courthouse. E.g.,

Marion County Clerk of Courts, FL
Marion County Courthouse, FL

Search for civil and/or criminal records on courthouse website under doctor’s name and/or company/organization name if the website has an internet search.

Copy and paste any records found and the URL of the courthouse website.
If there is no internet search, call the courthouse to see if they will do a case search by name.
If this costs money, check with the attorney first.

Order the complaint and final judgment for any divorce cases and any cases where the doctor/doctor’s company was the defendant. You will most likely have to send a written request.

Ask for the costs before you send the money.
Get prior approval for the costs from the attorney.

You may be able to find some of the judgments in the public records search online:

www.publicrecordcenter.com/onlinecourtrecords.htm

Check out this site to find states and cities the doctor may have lawsuits and licenses in.

8. www.trialsmith.com

Sign on with ID and password
Search by Last name and First name.
Note the number of depositions available in case attorney wants to purchase them.
Send similar searches. Send l0 emails to lawyers searching same doctor to find out what they have on the doctor and offer to share what you find.
Logout

9. Go to www.pubmed.gov and search for any publications that the doctor has written. Only copy and paste the Abstracts (which are free).

Type in the doctor’s last name and first initial and middle initial (with no comma, e.g., Smith JJ) in the “Search Pubmed for” box. Click on “Go.”
Scan the descriptions of the articles and see if they deal with areas that are related with the doctor’s specialty, if you can tell.
Cross reference the articles you find with the doctor’s CV (if available).
Click the box next to each article description that you believe has been written by the doctor you are researching. Go to the drop down menu that currently says Summary and change it to Abstract.
Copy and paste all the article abstracts and put them into your document.
Insert page breaks between each abstract.

10. Go to Google Scholar, scholar.google.com, and search for any articles written by the doctor.

Search articles by the doctor’s name or his initials and last name.
Click on the links and copy and paste the article abstracts by the doctor and the URL in a Word document.

11. Go to www.amazon.com and see if the doctor has written any books.