How to Minimize the Impact of Independent Medical Examinations

Dear Adjuster:

This will confirm our agreement to have our client, John Doe, evaluated on an independent basis by Dr. Mary Rowe, an orthopedic specialist with offices in Anytown, Anystate.

We have agreed as follows:

A. That you will provide me with a copy of your cover letter to the physician including any questions, comments, or other concerns to the doctor. Privilege is hereby waived on the part of both parties for purposes of this examination.

B. You will provide me with a copy of the doctor's complete report, without exception, within two weeks of receiving the report in your office. You will also provide copies of any subsequent report or cover letters relating to this matter. If you anticipate any delay with the above time frame, please let me know.

C. Dr. Rowe may be used by either party at trial or in any deposition procedure. You are also allowed to use any of my client's physicians at trial with appropriate notice as provided by the Anystate civil rules.

D. The cost of this examination will be absorbed totally by the carrier. The cost of any subsequent deposition or trial testimony will be absorbed by the party calling the witness to testify.

E. The cost of your...