Build a Deposition Outline for the Defense IME Doctor in a Personal Injury Case
Builds a deposition outline for the defense medical examiner from the IME report, treating records and CV you paste. Questions are tied to exhibits and sources, and the questions to be asked aloud are separated from attorney-only strategy notes.
The Prompt
Variables (8)
| Variable | Description | Example |
|---|---|---|
| {{ime_doctor_name}} | IME Doctor Name | Robert Hayes, M.D. |
| {{ime_specialty}} | IME Doctor Specialty | Orthopedic surgery |
| {{court_and_governing_rules}} | Court and Governing Rules | Circuit Court of Cook County, Illinois. Pasted: the rule on physical examinations and the scheduling order dated 08/05/2026. |
| {{key_disputes}} | Key Disputes | IME states the C5-C6 herniation is degenerative; treating surgeon states it was caused by the 03/12/2026 collision. |
| {{attorney_instructions}} | Attorney Instructions | Lead with materials reviewed. Do not ask about the examiner's income unless the CV supports it. |
| {{ime_report}} | IME Report | Report dated 06/09/2026: "Examination lasted approximately 20 minutes. Diagnosis: age-related cervical spondylosis." |
| {{treating_records}} | Treating Records and Opinions | Dr. Patel 04/02/2026: "No neck complaints documented before 03/12/2026; MRI shows C5-C6 herniation consistent with acute injury." |
| {{cv_and_prior_testimony}} | CV, Fee Schedule and Prior Testimony | CV (3 pages), fee schedule dated 01/2026, transcript excerpt from Smith v. Allied (2024). |
Expected Output
Part 1: evidence register, conflicts, arithmetic, an examination adequacy map, a table tying each question to its exhibit and source, declined items, missing information. Part 2: numbered, marker-free deposition questions by section. Closes with a Verification list.
Usage Notes
Use after you have the IME report, the treating records and whatever the examiner has produced (CV, fee schedule, prior testimony). Paste actual text. Watch for clinical tests or imaging terms the records never mention, dates checked against a publication the examiner merely cites, and questions that assume a fact only your theory states, or that treat silence in the report as proof something was not done. Read the document part line by line before it leaves the office; the questions must be usable aloud without the notes. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Legal Sources Referenced
- Fed. R. Civ. P. 35(a)(1) (court may order a party whose condition is in controversy to submit to an examination by a suitably licensed or certified examiner)
- Fed. R. Civ. P. 35(b) (examiner's written report: findings, diagnoses, conclusions and test results; request for earlier reports)
Originally featured in: AI for Personal Injury Lawyers: Prompts for Demand Letters, Medical Summaries & Depositions
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* These prompts are drafting and analysis aids for licensed attorneys. They are not legal advice and do not replace professional judgment. AI output can contain errors, including invented citations and incorrect deadlines: verify every fact, figure, authority and deadline against primary sources before relying on it. Rules vary by jurisdiction, and you remain responsible for the final work product.