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Articles Posted in Discovery

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Defendant’s Motion to Compel IME

Last week, a well-respected defense lawyer told one of our lawyers they possessed the Maryland Trial Lawyers Association’s “Handbook,” which spells out the terms for a defense requested medical examination. This “Handbook” has made its way into a Motion to Compel a Physical Examination, specifically including this “MTLA Handbook” as…

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Independent Medical Exams: Personal Injury Attorney Cross-Examination of Defendant’s Medical Expert

A few days ago, I wrote about a judge’s article entitled Alice in Discovery Land (A Practical Guide to Recurrent Discovery Problems) that appeared years ago in Maryland Litigator, quoting Judge Smith’s comment about the oxymoronic phrase independent medical exam. Counsel on both sides of the aisle have their own…

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