| name | expert-witness-omissions |
| title | Expert Witness Medical Records Omissions Analysis |
| description | Identifies medical records an expert witness failed to review, cite, or address by cross-referencing the expert's materials-reviewed list against the full case record set. Produces a tiered omissions register, methodology critique, bias analysis, and strategic recommendations for cross-examination and exclusion motions. Use in personal injury or medical malpractice litigation when challenging or defending expert credibility during discovery, pre-trial, or trial preparation. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/expert-witness-omissions |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | personal-injury |
| language | en |
| tags | ["analysis","litigation"] |
Expert Witness Medical Records Omissions Analysis
Surfaces gaps in an expert's medical record review to support impeachment, exclusion motions, and rebuttal strategy.
Prerequisites
- Expert materials — reports, deposition transcripts, disclosed materials-reviewed list
- Complete medical record set — clinical notes, labs, imaging, operative reports, pharmacy records, consult notes
- Case context — expert's stated opinions and the claims or defenses they support
Output Structure
1. Materials Reconciliation Table
| Record / Document | Date | In Case File | Cited by Expert | Gap |
|---|
| {Record name / provider} | {Date} | ✓ | ✗ | Omitted |
List every record in the case file. Flag all not cited or addressed by the expert.
2. Omissions Register
For each omitted record:
| Field | Detail |
|---|
| Record | Name, date, provider, Bates/page cite |
| Expert's assertion | Verbatim quote + transcript/report cite |
| Omitted content | Key findings, values, diagnoses, clinical events |
| Significance tier | Critical / High / Moderate / Low |
| Inadvertent or strategic | Assessment with reasoning |
Significance tiers:
| Tier | Meaning |
|---|
| Critical | Directly contradicts expert's core opinion or key factual assertion |
| High | Documents pre-existing conditions, alternative causation, or ignored treatment decisions |
| Moderate | Fills timeline gaps or undermines methodology without negating the opinion |
| Low | Minor oversight unlikely to affect substantive conclusions |
3. Methodology Critique
