For Solicitors — Briefing a Neurologist for an IME | Dr Ron Granot

For Solicitors — Briefing Dr Granot for an IME

A clear brief produces a clear report. This page is a practical guide for instructing solicitors — what to include, the scope of opinion, and what to expect at each stage.

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The Brief That Produces a Better Report

The single biggest determinant of report quality is the brief. A vague request — "report on this client's neurological condition" — produces a vague report. A focused brief with specific questions, complete records and a clear scope of opinion produces a focused report that addresses the actual matters in dispute.

Dr Granot accepts briefs from solicitors acting for plaintiff, defendant, and insurer interests. The same standard of independent assessment applies regardless of the instructing party.

Brief Submission Checklist

1. Letter of instruction — what to include

  • Matter type — SIRA WPI, PIC, common law, TPD, medical negligence, fitness for work, Defence, other
  • The questions you want answered — specifically, not generically. See examples below.
  • Relevant legislation or rules the assessment is conducted under (e.g. NSW Motor Accident Injuries Act, Workers Compensation Act, PIC procedural rules)
  • The role of the report — primary opinion, addendum to a prior report, response to another expert's opinion, supplementary on specific issues
  • Acknowledgement of expert duty requirement (Expert Witness Code of Conduct under UCPR for court matters)
  • Deadline for the report if any

2. Documents to provide

  • Statement of claim / index to court documents (where relevant)
  • All available medical records — GP, hospital admission summaries, specialist letters, imaging reports
  • Allied health records (physiotherapy, psychology, neuropsychology, occupational therapy)
  • Imaging reports and, where possible, access to actual imaging studies (MRI, CT, X-ray) for independent review
  • Prior medicolegal reports — both plaintiff and defendant experts
  • Employment records, job description, work capacity certificates (work injury / TPD)
  • Police report / event timeline (motor accident / personal injury)
  • Plaintiff's own statement of how the injury happened and how symptoms have evolved

3. Logistical detail

  • Client's contact details for appointment confirmation
  • Whether an interpreter is required (and which language)
  • Mobility considerations (wheelchair access, support person)
  • Confirmation of acceptance of fees (quote provided on receipt of brief)

Examples — Vague vs Focused Instruction

Same client, same documents, very different reports. The focused brief produces a useful report; the vague one produces a long but unhelpful one.

❌ Vague brief

"Please assess Mr X's neurological condition arising from the motor vehicle accident on [date] and provide a report."

✓ Focused brief

"Please assess Mr X's neurological injuries arising from the motor vehicle accident on [date], specifically addressing: (1) diagnosis of any traumatic brain injury and its severity; (2) presence of post-concussion syndrome and its likely duration; (3) any peripheral nerve injury and prognosis; (4) Whole Person Impairment under the SIRA Permanent Impairment Guidelines, fourth edition; (5) work capacity for his pre-injury role as a [occupation]; (6) likely need for future neurological treatment, rehabilitation, and review."

The first instruction generates a sprawling narrative summary. The second produces a structured report directly answering each question in turn — far more useful in negotiation, mediation or court.

Scope of Opinion

Different matter types call for different opinion scopes. The brief should make the scope explicit.

SIRA WPI

Permanent Impairment under the NSW SIRA Permanent Impairment Guidelines (currently 4th edition for motor accident; AMA Guides 5th edition for workers compensation neurology). Maximum medical improvement required.

PIC Medical Assessment

Following PIC procedural rules and referral terms. Specific questions defined in the referral.

Common Law / Negligence

Diagnosis, causation, prognosis, treatment needs, future care, work capacity. Conformity with Expert Witness Code of Conduct (UCPR Schedule 7 NSW).

TPD / Superannuation

Whether the claimant meets the policy's definition of total and permanent disability — requires careful review of the specific policy wording, which should be provided with the brief.

Medical Negligence

Whether the standard of care was met. Causation of harm. Damages. Independent peer review.

Fitness for Work / Defence

Capacity for a defined role with neurological conditions. Risk of recurrence (e.g. seizure, syncope). Driving fitness.

What Happens After the Brief Is Received

StepWhat happensIndicative time
1. Brief receivedEmail or post. Acknowledgement returned with quote (if not pre-agreed) and proposed examination date.Within 1–2 working days
2. Examination bookedDirect booking with the client. Confirmation back to instructing solicitor.Typically within 2–4 weeks
3. ExaminationIn-person assessment at Bondi Junction rooms. Comprehensive history + neurological examination. Typically 45–90 minutes depending on complexity.Single appointment
4. Report draftedReport addresses each question in the brief structurally. Includes Expert Witness declaration where required.1–2 weeks from examination
5. DeliveryReport emailed to instructing solicitor. Original posted if requested.
6. Optional addendumAddenda for additional questions, supplementary records, or response to opposing opinion handled separately.1 week typical

Submitting the Brief

Briefs can be submitted by email (preferred for speed) or by post:

Please send the complete brief package in one go where possible — supplementary material received late delays the assessment. Where supplementary documents arrive after examination, addenda can be prepared.

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Typical turnaround 1–2 weeks. SIRA + PIC accredited.

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AddressSuite 301, 251 Oxford Street, Bondi Junction NSW 2022
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