In the trial of a personal injury action, the defendant's insurance carrier will invariably hire litigation doctors on its behalf to examine the plaintiff in order to testify at trial for the purpose of assisting in the defense of the case with respect to the damages suffered by the plaintiff. These "hired guns" will opine that: the plaintiff did not sustain any injury as a result of the subject incident and/or has made a complete recovery. These highly paid professional witnesses are usually experienced and skilled at convincing a jury of their "expert" opinions.

This CLE course is designed to teach the plaintiff's attorney how to use the adverse party expert that performed the Insurance Medical Examination [IME] to help prove the plaintiff's case, and undermine these negative opinions and attack the credibility of this witness.

This class will go through the structure, elements and style of an effective cross-examination, and the necessary preparation to properly execute a winning cross-examination. We will review a typical negative IME, and show how to win a significant plaintiff's verdict by using the techniques taught in this class. Actual questions and answers from real cases will be used to illustrate the power of a "positive" cross-examination, and how and when to impeach the witness and show their bias.