# Cite every finding to a record the other side can test

> Plaintiff and defence IMEs fail when you cannot prove what the examiner had, and when.

Source: https://imecore.com/use-cases/med-legal

## Opposing counsel asks what the examiner saw. You have a PDF pile.

The instructing letter asked five questions. The bundle has no index. Exhibit numbers in the report do not match the brief. A missing consent turns up after you have already served the report. Rebuilding the chain takes a paralegal a day.

- You cannot show which records the examiner actually received.
- The chronology is rebuilt by hand for every matter.
- Bates numbers drift between the bundle and the report.
- A late opposing report lands and the original file is already closed.
- Trial dates sit in counsel's calendar, not on the case.

## What IMECore does about it

### A record set you can prove

Each document carries its source, its date, and when the examiner received it. Export the list as an exhibit index.

### The chronology is a draft you correct

IMECore reads dates and providers out of the records. You fix the timeline. You do not type it from scratch.

### Instructing questions in, answers out

Your questions sit on the case. The reviewer confirms each has an answer before the report is served.

### Disclosure on assignment, not later

Conflict and prior-treatment disclosures are recorded when the examiner is named. Privilege stays in a separate class.

### Bates numbers that match the brief

Stamp the bundle once. Citations in the report point at those numbers, not at a second unofficial set.

### Testimony terms on the file

If the examiner may be called, the case holds the fee terms and the dates already committed.

## How it runs

1. **Send the instructing letter.** Forward it to intake. IMECore reads counsel, the questions, and the date the report must be served.
2. **Build a sourced brief.** Attach records with dates, stamp Bates numbers, and draft the chronology for a person to check.
3. **Assign the examiner and disclose.** Name the examiner, record conflicts, and send the brief with the questions in view.
4. **Cite, review, and serve.** Check each answer against a record citation, then release the report and the exhibit index.

## Numbers worth knowing

| Figure | What it measures | Source |
|---|---|---|
| $2,165 | Doctors of BC recommended fee for a medico-legal opinion report | Doctors of BC uninsured services guide, 2024 |
| $3,457 / day | Doctors of BC recommended testimony fee | Doctors of BC uninsured services guide, 2024 |
| 6% | Cap on recoverable disbursements in many BC vehicle-injury actions | BC Reg 210/2020 |

## Questions people ask

### Can we name our own examiner?

Yes. Put the examiner on the instructing letter, or let the coordination firm assign from its panel. Conflict disclosure still sits on the case.

### How is privilege handled?

Instructing letters and privileged material sit in a separate class. The examiner portal does not show that class.

### Do you produce a chronology we can file?

IMECore drafts a dated, sourced chronology from the records. Export it as a table. A person reviews it before it leaves.

### What if the other expert serves a report?

Open a rebuttal on the same case. It inherits the record set and links to the original opinion.

### Which provincial rules apply?

The case carries the province. Ontario and BC files use different report headings and tax. Limitation periods are yours to set as dates on the case.