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How to Prepare for an IME in a Maryland Injury Case \| CallAmir.com

CallAmir.com · Maryland Personal Injury · Article 20

How to Prepare for an IME

Walking Into the Defense Medical Exam Ready, Honest, and Protected

If your Maryland injury claim has reached the point where the defense has scheduled an "independent medical exam," or IME, the natural reaction is worry. That is understandable. But an IME is not something to fear if you understand what it is and prepare properly.

Remember what the exam actually is: a medical evaluation performed by a doctor the defense selected and paid, for the purpose of building the defense's case. It is not a checkup, and the doctor is not there to help you get better. That reality is exactly why preparation matters.

You do not beat an IME by being clever. You get through it by being honest, consistent, and prepared.

Before the Exam

Good preparation starts days before you walk in the door.

★ Speak with your attorney first Know the basics before you go: the date and location, the name of the examining doctor, and the _scope_ of the exam. In a Circuit Court case, that scope is defined by court order under Maryland Rule 2-423 — the exam is supposed to stay within it. Your attorney can tell you what to expect and what your rights are.

Review your own history so your account is accurate and consistent. You do not need to memorize dates, but you should be able to describe honestly how the injury happened, how it has affected you, what treatment you have had, and what still hurts. Inconsistency — not injury — is what defense lawyers hunt for.

• Arrive on time, or a few minutes early. Missing or being late to a properly ordered exam can genuinely harm your case.
• Bring a valid photo ID and anything your attorney specifically asks you to bring.
• Dress normally. Do not put on a performance in either direction.
• Ask your attorney whether someone may accompany you, and whether the exam may be recorded — the rules can allow reasonable conditions.

During the Exam

The exam has already begun before the doctor introduces themselves. You may be observed in the parking lot, the hallway, and the waiting room. Assume you are being watched the entire time, and simply act as you normally would — because that is the truth of how your injury affects you.

★ Tell the truth — completely Describe your pain, your limitations, and your daily struggles honestly. Do not minimize them to be polite, and do not inflate them to strengthen your case. Both are dangerous. Minimizing hands the defense a quote that you are "fine." Exaggerating hands them a chance to call you a liar. The honest, consistent account is the strong one.

⚠ Do not make small talk about how you feel An offhand "I'm having a good day" or "the drive wasn't bad" can be written into the report and quoted against you later, stripped of context. Answer the questions you are asked. Do not volunteer commentary about your condition.

⚠ Do not guess, and do not speculate If you do not know the answer, or cannot remember, say exactly that. "I don't recall" is a complete and honest answer. Inventing details to seem cooperative creates contradictions that surface later at the worst possible time.

⚠ Do not let the exam wander outside its scope If the examiner probes into matters that have nothing to do with your injury, you are allowed to say you are there for the ordered exam. This is one more reason to know the scope beforehand and to have counsel involved.

After the Exam

As soon as you leave, write down what happened while it is fresh in your memory.

• How long the exam actually lasted — sometimes far shorter than the report suggests.
• What the doctor physically did, and did not do.
• What questions were asked, and what you answered.
• Anything said in the hallway or waiting room, by anyone.

Then hand those notes to your attorney. Keep them private. If the eventual report describes a fifteen-minute exam as thorough and complete, your contemporaneous notes may be the record that shows otherwise.

The Mindset That Protects You

An IME rewards the prepared and punishes the careless. The plaintiff who tells the truth, stays consistent with their medical history, avoids casual chatter, and reports back to counsel afterward has very little to fear. The plaintiff who tries to outsmart the doctor, minimizes to be polite, or exaggerates to make a point often hands the defense exactly what it was hoping for.

Preparation is not about saying the right magic words. It is about walking in with the truth, and walking out with a record of what really happened.

This article is for general educational purposes only. It is not legal advice and does not create an attorney-client relationship. Maryland law changes, and every case turns on its own facts. If you or someone you love has been injured, speak with a Maryland personal injury attorney about your specific situation before making any decisions.

If you have been injured in Maryland, do not speak to the defendant's insurance company, their adjuster or attorney, it may jeopardize your case. Contact The Guerami Law Firm, LLC through CallAmir.com for a confidential consultation with Amir Guerami and his team.