Expert Report Services
Urgent Care Expert Witness Reports & Affidavits
"Attorney-Proof" Medical Opinions Designed to Withstand Scrutiny
In medical malpractice litigation, the expert report is often the blueprint for the entire case strategy. A vague or conclusory report can crumble under cross-examination or fail to support a Motion for Summary Judgment.
Dr. Max Lebow creates comprehensive, defensible expert reports that articulate the Urgent Care Standard of Care with precision. Whether you need a preliminary opinion letter for settlement discussions or a detailed Federal Rule 26 report for trial, Dr. Lebow's written work is crafted to anticipate, and neutralize, opposing arguments before they are even raised.
The "Attorney-Proof" Approach
Dr. Lebow drafts every report with the assumption that it will be aggressively challenged. To ensure durability, he employs a specific methodology:
Anticipating Objections
Instead of simply stating an opinion, Dr. Lebow anticipates the opposing counsel's likely challenges and addresses them directly within the body of the report.
Defending Every Word
Each conclusion is supported by the medical record and the specific Standard of Care for Urgent Care medicine, minimizing the wiggle room for opposing counsel during deposition.
Plain Language Clarity
While medically precise, the rationale is explained in clear, accessible language that a judge or jury can understand, bridging the gap between complex medicine and lay interpretation.
Types of Written Reports
Affidavits & Certificates of Merit
Many jurisdictions require an expert's affidavit to file a medical malpractice lawsuit. Dr. Lebow provides timely, compliant reviews to satisfy state requirements, confirming that a reasonable basis for the action exists based on a breach of the Urgent Care Standard of Care.
Comprehensive Expert Reports
For discovery and trial, Dr. Lebow produces detailed reports that serve as the foundation of your case theory.
- Standard of Care Analysis: A detailed breakdown of what a prudent urgent care provider would have done under similar circumstances.
- Causation Analysis: A forensic examination of whether the alleged breach actually caused the damages, or if the outcome was inevitable regardless of the intervention.
- Timeline Reconstruction: A factual chronology of the patient's care, identifying exactly where the deviation occurred.
Rebuttal Reports
When opposing counsel retains an expert, often an Emergency Medicine or Family Practice doctor, who misapplies the standard of care, Dr. Lebow writes rebuttal reports that expose these methodological errors.
- Correcting the Standard: He clarifies why ER standards (like immediate access to CT scans) do not apply to the urgent care environment.
- Challenging Hindsight Bias: He demonstrates how the opposing expert is using retrospective knowledge rather than evaluating the patient's presentation in real-time.
Motion for Summary Judgment (MSJ) Support
For defense counsel, Dr. Lebow creates reports specifically tailored to support dispositive motions. By clearly establishing that the care provided was reasonable and within the standard, these reports can help resolve cases before they reach a jury.
Our Reporting Philosophy: "Strengths and Weaknesses"
Dr. Lebow does not act as a "hired gun" who ignores inconvenient facts. His reports provide a balanced view, highlighting both the strengths and the weaknesses of the case.
Why This Helps You
Identifying weaknesses early allows you to prepare for them, rather than being ambushed at trial.
Credibility
This objective approach enhances Dr. Lebow's credibility with the court, as he is seen as an evaluator rather than a partisan advocate.
The Review Process
Thorough Record Review
Dr. Lebow reviews every page of the medical record, not just the summaries. He often finds critical evidence in nursing notes, triage logs, or vital sign sheets that significantly impacts the case.
Draft & Review
Draft reports are discussed to ensure they address all legal theories while remaining medically accurate.
Finalization
The final report is delivered promptly, often within 2-3 weeks of retaining the file.
Need a Defensible Opinion?
Don't settle for a generic medical report. Get an opinion rooted in the specific realities of Urgent Care medicine.