Deposing the ERISA/LTD Physician
| Author | Dorothy Clay Sims |
| Pages | 931-940 |
21-1
DEPOSING THE
ERISA/LTD PHYSICIAN
CHAPTER 21
DEPOSING THE ERISA/LTD PHYSICIAN
I. GOVERNING PRINCIPLES
§21:01 Claimant’s Lawyer’s Role: Gather More and Better Evidence
§21:02 Common DME/Defense Tactics
[§§21:03-21:04 Reserved]
II. RESPONDING TO COMMON DEFENSE TACTICS
§21:05 Look for Weaknesses in DME’s Report
§21:06 Advise Client to Keep a Diary
§21:07 Complete the Record
§21:08 Point Out Inconsistencies in Carrier’s Advertisements
§21:09 Provide Carrier With Background Material on Its DME
[§§21:10-21:11 Reserved]
III. SAMPLE QUESTIONS
§21:12 Background and Bias
§21:13 Questions About Plaintiff’s Job
§21:14 Questions About the Medicine
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