DANCING WITH WOLVES IN DRAG A TEXAS PLAINTIFF ATTORNEYS PERSPECTIVE ON TACTICS AND STRATEGY INVOLVING ADVERSE MENTAL AND PHYSICAL EXAMS And what big teeth you have Grandma PAUL N GOLD ID: 768344
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“DANCING WITH WOLVES IN DRAG” A TEXAS PLAINTIFF ATTORNEY’S PERSPECTIVE ON TACTICS AND STRATEGY INVOLVING ADVERSE MENTAL AND PHYSICAL EXAMS
“And what big teeth you have, Grandma!”
PAUL N. GOLD AVERSANO & GOLD HOUSTON , TEXAS WWW .CUTTING EDGE JUSTICE. COM
CONFRONTING MYTHS
WHO MAY BE SUBJECT TO AN ADVERSE EXAMINATION
REQUESTING THE ADVERSE EXAM
THE INFORMAL REQUEST FOR ADVERSE EXAM
MOTION FOR AN ADVERSE EXAM
IN CONTROVERSY
GOOD CAUSE
LEVELING THE PLAYING FIELD: THE EVISCERATION OF THE LESS INTRUSIVE MEANS TEST
In re H.E.B.
TIMING OF REQUEST FOR ADVERSE EXAMINATION
SCOPE OF AND LIMITATIONS ON EXAMINATION
NATURE AND EXTENT OF EXAMINATION
THIRD PARTY ATTENDANCE AT EXAMINATIONS AND RECORDING INTERVIEW-EXAMINATION
WHO MAY CONDUCT THE EXAMINATION
NUMBER OF EXAMINATIONS
TIME PLACE AND EXPENSE
PROTECTION FOR PROTRACTED, UNDULY INTRUSIVE OR PAINFUL EXAMINATIONS
THE ORDER
THE REPORT
SCOPE OF DISCOVERY
DISCOVERY ABOUT THE EXAMINEE
DISCOVERY ABOUT THE EXAMINER
PRODUCTION OF DOCUMENTS, DATA, AND THINGS GENERATED AND CONSIDERED
DAUBERT/ROBINSON
SANCTIONS
SPOLIATION
TRIAL
EXAMINEE CALLING THE EXAMINER AS A WITNESS AT A TRIAL
IMPEACHMENT
APPENDIX – CAST STUDY DOCUMENTS