Wednesday, January 25, 2017

Story of the Apricot™ - Cross Examining Psych Doctors, Tip #60

An Apricot™ is a clearly written work product privileged report that describes all of the substantial flaws in a psych report in jargon-free language and discusses specific techniques to cross-examine the doctor.  An Apricot™ also provides a list of simple questions to ask the doctor that will reveal the flaws found in their report.  The name Apricot™ comes from the color of paper available in our office.  The story goes that since the 1980s any referral for an evaluation of an applicant received in my office is printed on bright orange paper.  The bright-colored paper is easily identifiable in the patient’s chart.  As a result, my office staff calls any referral for a workers’ compensation evaluation an “orange.”  Similarly, referrals for the evaluation of a personal injury psych evaluation are printed on lime-colored paper and called a “lime.”  In 2009 I began to assist attorneys with written pre-deposition / pre-trial consultation reports.  I quickly realized that “pre-deposition / pre-trial consultation report” is a mouthful, and a simpler, shorter name was needed.  I decided to go with Apricot™. 

When you want an Apricot™, simply call my office or email the psych report to me with a brief cover letter.

More help for cross-examining psych doctors can be found at my website ( and in my book Psychological Evaluations In Litigation: A Practical Guide for Attorneys and Insurance Adjusters

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