Writing the Civil Psychiatric IME Report a New York Cross-Examiner Cannot Take Apart

Stephan M. Carlson, MD, MBA, FAPA · Civil Psychiatric IME

A civil psychiatric IME report is written for a skeptical reader. Opposing counsel will look for the gap between what the examiner observed and what the examiner concluded. The report that survives is not the one with the strongest language. It is the one in which each step from record to examination to opinion is visible. The report begins with the procedural frame A New York civil mental examination is authorized because a party has placed mental condition in controversy. CPLR 3121 provides the examination mechanism. In personal injury, disability, and death actions, the exchange of medical information is governed by 22 NYCRR 202.17. The report therefore functions as litigation disclosure,

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