• We requested all medical records, police, and EMS report from the scene of the accident. We performed a thorough file review and documented pre-existing injuries, prior pain complaints, and previous surgical procedures. We determined Jeffrey’s complaints of injury to his back, neck, and left hand in the motor vehicle accident were not new injuries, but exacerbation of pre-existing injuries.
  • We advised the attorney of our findings, and recommended documentation of our review and offered to make arrangements for an IME to determine if another doctor concurred with our findings. The attorney agreed and requested that we make these arrangements, attend the IME, and provide her with a copy of our report.
  • The IME was completed by a Physical Medicine and Rehabilitation physician, due to the multiple pre-existing injuries and treatment provided. We completed a detailed history letter and provided copies of all relevant medical records for the physicians review prior to the evaluation. In our letter we requested that specific questions be addressed during the evaluation.


We received a copy of the PM&R physician’s IME and completed a thorough review of his findings.  His results indicated the only injury that could be attributed to the MVA was the injury sustained to the left shoulder. We completed a detailed report including our findings, a rebuttal to Jeffrey’s treating physician, and a copy of the IME. We provided a copy to the attorney, the claims adjuster, and Jeffrey.



The defense attorney for the insurance carrier was able to use our report to prove the insurance company was not responsible for payment of treatment for injuries and pain unrelated to the motor vehicle accident involving his insured.  She was able to settle with Jeffrey for an amount well below the policy limits.