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Why not send someone who has expertise and true experience to your next cross examination on issues such as………

 

 

AMA Guides

Almaraz Guzman/ FCE

Apportionment

Benson

Brain Injury

Dentistry

Escobedo

Eyes

Fresno PQMEs

Internal Medicine

Neurology

Neuro-Cognitive

Orthopedic Medicine

Pain Disorders

Psychiatry

QME Regulations

Sexual Disorders

Sleep

Treatment/Home Care/ Home Modifications

 

just to name a few?!   Ask and I will tell you if I have done such depositions.   If it is a specialized area, I will do the research necessary at no extra charge.

 

Check what I offer and my rates!


FREE OF CHARGE:  Consultation in choosing the right AME (and warning about the wrong one) for your case. Just call or e mail with the proposed selections and/or information about your case.  

 

Report Review:   For only $75 per report,  I will tell you whether I recommend cross examination, or an interrogatory, or not.   If an interrogatory is suggested, I will write it for you at no extra charge!  I have had great results with a simple interrogatory which can produce a supplemental report of significant worth.   My preference is always to avoid cross exam if an interrogatory is likely to achieve the same result.  If I recommend cross exam, and then you choose to utilize my services the review of one report (of the same doctor deposed)  will be  deducted from the cross examination (unless you are already paying our lowest bulk rate) .  I will not make that deduction unless you resend the memo to me 1 week prior to the cross exam so that I can use it to assist in my preparation.   I prefer hard copy which would be mailed to Brad Wixen/Cross Exam Experts:   361 N. Alta Vista Blvd.   Los Angeles, CA 90036.   If the matter is urgent, you can scan the report(s) to me or send by fed ex.   It is important that I know what body parts are alleged as injured to compare this as against the exam.   If there is a more recent PTP report or testing not reviewed, please provide that to me as well as any other information that you wish for me to consider.  (It is often helpful if you have some information from your own office as to how applicant is currently doing and her willingness to wait for further workup.)

 

What are my criteria?  The main ones include:  

*The quality of the rebutting PTP. (The greater the quality of the PTP, the less likely the necessity of a cross exam.)

*The discrepancy between the PTP and the AME or QME.  (The greater the discrepancy, the greater benefit of a cross exam.)

*Whether the report is fatally flawed on its face.  (If the report is so fatally flawed on its face, I would recommend no cross exam and will write a letter to the PTP free of charge asking for rebuttal and outlining the issues and/or prepare  a short brief outlining the flaws for an additional charge---- see below.)

*Whether the physician made an error that can not be overlooked.  (If there is an error, the greater the likelihood to recommend cross exam.)

* Whether the value of the gain merits the cost of a cross exam versus a simple interrogatory.

*Whether there is a great discrepancy between the functional loss and the rating provided.  (I.E., an Almaraz Issue.)

*Whether the physician involved is likely to reconsider.

*Whether the examination and rating were performed properly.  

 

Cross Examination

PLEASE BE AWARE THAT YOU CAN LEAVE THE WORK TO US.    AT NO EXTRA CHARGE, WE CAN DO ALL THE SCHEDULING.   WE CAN EVEN RESERVE A COURT REPORTER.  JUST LET US KNOW WHAT YOU NEED, AND SEND OUT THE NOTICE AND THE FEES AND WE WILL FREE UP YOUR SUPPORT STAFF FOR OTHER MATTERS!

For only $600 I will prepare, attend and conduct cross examination with a summary of relevant highlights.   This price will not go up regardless of the complexity or if the time inadvertently goes longer. (However, for any cross examination that goes the majority of a second hour, there will be an extra charge of $75 per hour.)  I can tell you that the cost of my work over the last few years has produced revenue far surpassing my salary and most cross examination come away with tangible gains that more than pay my cost, while saving you the necessity of a salaried attorney.   If your firm uses me regularly (for 3 or more tasks in any given week), the "bulk rate" will apply of $500.00.   If I am given the wrong information when the deposition is reserved regarding the length of the deposition, the time, the date, or otherwise, we bear no responsibility to attend and will not subtract charges owing to such errors. 

I will try to attend all cross examinations within a 40 mile radius of my location (but reserve the right to conduct any deposition by phone if I am unable.)  

If you wish for me to personally attend a cross examination of more than 60 miles radius, I will do so for no extra charge if you schedule two cross examinations in the same location on that day.    Otherwise, I will charge you for reservation of two cross exams ($1200) plus the cost of AMTRAK round trip.   

On rare occasion, I am asked to  attend a defense cross examination in which case I write a full letter along with the appearance and the bulk rate is $1,000.00-$1200.00 depending on complexity.   If I am asked to travel and spend the entire day for the cross exam, I will charge for 2 cross exams plus reasonable travel.    

I would request whatever information you want me to review arrive at least one week in advance of the cross exam and prefer hard paper to review.   Preferably I like to receive:    1.  All AME or PQME reports in all specialties.    2.    Any reports or studies including PTP performed after the AME or QME report, especially if the PTP reviews and comments on the reporting.   .   3.   Any recent office notes regarding contact with the applicant.   4.   Any final report by the PTP.   5. Any important new documents that the doctor being deposed has not yet reviewed.   I don't want to skip "your issue" so if there are special issues or concerns,  please let me know what you want me to cover and I will do so but of course reserve the right to pursue other issues as well.  Otherwise, I will work with whatever you do provide me.   Many offices provide me with their entire file.   Some provide simply the reports by the physician being deposed. I will work with whatever you send me.     I prefer hard copy if you can mail or have delivered whatever you wish for me to review to my address:   361 N. Alta Vista Blvd. LA, CA 90036.   If there are less than 8 reports, you may scan them to our e mail and we can print them.     Our clients are responsible for providing the necessary file before the cross exam.   We will return up to 2 boxes via FEDEX at our own expense.   For more than 2 boxes, we do submit an extra charge.  

Methods of Deposition:

There are three methods.   1.   In Person.   2.  By the Doctor's Speaker Phone.  3.  Remote Audio Equipment to be supplied by Atkinson-Baker.    The most common method of deposition is in person.   I try to attend all of my depositions in person and am successful at doing so the majority of the time,  but sometimes due to transportation, scheduling, or unforeseen circumstances, I reserve the right to call in.  In my experience, being there in person makes very little difference and almost never has an effect on the outcome.    Sometimes, the doctor or the opposing counsel will object that they did not have advance notice that we will conduct the deposition by phone.   Therefore I recommend on all of our deposition notices include the words:  "We reserve the right to conduct the deposition telephonically."   If the deposition is being done by opposing counsel, and I know in advance that I can only be there by phone, I may ask you to advise opposing counsel that we will be attending their cross exam by phone.   If we know that a cross exam will not occur in person, it is important to verify ahead of time that the doctor has a speaker phone.  We may ask your assistance with this, unless we know from prior experience that they can accommodate.      However, even if the doctor does not have a speakerphone, there is a third option.   We have a Court Reporter, Atkinson-Baker, with remote audio access and a speaker who we can reserve to set up a remote speaker to conduct the cross examination.   As far as we know Atkinson Baker is the only Court Reporter who has this equipment which we purchased and so if the cross exam will not be in person, and the doctor has no speakerphone, then please let us know to reserve Atkinson-Baker and again include on your notice that the deposition will be conducted telephonically.   If any of this sounds confusing, it is not really, just call us and we can explain it further.  

Cancellations:   If there is a cancellation for any reason more than 1 week prior to the cross exam, there will be no charge.   If the cancellation is within the same 24 hr period, then the charge is full price.  More than 24 hours but the previous day is 50%.    If I have prepared the file, there will be a charge for that preparation.   Otherwise, any cancellations within one week will be charged $75.   I hope you will appreciate that in some weeks, the cancellations are as much as 40-50%.    In addition, I reserve time and then turn down other appearances.   And, there is often overhead even in a cancelled appearance. 

We are not responsible for any notice errors on the part of the handling attorney.    It is the handling attorney's obligation to notify as to any changes or cancellations.  

We are grateful that "cross examination experts" is becoming more popular.   However, with success also comes some challenges.   But, with challenges, comes better solutions.  Many firms use us "at the last minute" to fill a void.   This is "hit and miss" and as our schedule fills, "misses" become more likely.   Brad really dislikes turning down any assignment.   In addition, the key to our long term success will be our ability to be "in on the process" from the beginning.   In light of this, we have decided to offer a new service:   You can unburden your already burdened support staff by simply providing us with all of the case information necessary, and we will make all of the arrangements for the deposition including calls to the physician's office and opposing counsel, and even the court reporter.   This is optional but we hope that it will make your life easier and ours a continued success!  Our client must still send the payment to the doctor and the court reporter, and the notice when we advice as to the selected date.  

Please note that we reserve the right to cancel any and all pending assignments should outstanding invoices exceed three months.

 

Legal Briefs

 

  1. If the report on the face of it, is not substantial evidence, and does not require cross examination, then for a $400 fee, I will prepare a short brief outlining why the report is fatally flawed and can not be relied upon.
  2.  Post Cross Exam it sometimes occurs, for instance,  that I represent that the opinions regarding apportionment have been rendered illegal and/or that the Panel report has been rendered illegal or inadequate for other reasons.   For $400, I will prepare a brief correlating the testimony with relevant provisions of the AMA Guides or Regulations to explain our position.

 

Seminars

 

I will give a half day ($600) to full day ($1,200) seminar at your firm on a topic of your choice .   Suggested topics would include:    The difference between DRE II and DRE III, radiculopathy, understanding diagnostic studies, the QME regulations, protocol for depositions, pain disorders, apportionment, or learning to analyze reports in internal, orthopedic, or psychiatric medicine.   Or, a topic of your choice!  

Civil and Defense:

I do consult and conduct IME depostions on civil cases and provide consultation and opinion to defendants and there is a different fee structure for these assignments.  

Please give me a try!    I am eager to make my customers happy!

Please e mail Erika at our address crossexamexpert@gmail.com  for further information, or to reserve your date or place your order. You can also call her at 323-738-1917   Or if you can't reach Erika, you can leave a message at our office phone number of (310) 205-2565.  I have "instant blackberry access" at crossexamexpert@gmail.com.   I am happy to schedule any date in which I am available.  However,  the way to insure that I am reserved for your cross examination is to set the deposition with my office originally.   Please call when you are scheduling to guarantee that we can attend.  Unfortunately, if it was not set originally, your date may be taken.   I reserve dates for whomever sets the deposition first.   So please reserve your dates as soon as you can.    Checks are to be made to "Cross Exam Experts".   You may also choose to pay utilizing paypal utilizing my e mail address above.    

Thank you!   

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