An opinion that overreaches in the report is a liability on the stand. Deposition-safe writing is a discipline, not a tone.
A physician can be right and still be discredited if the written opinion claims more than the records support. Deposition-safe writing states only what the medicine establishes — and says so plainly.
No outcome language
Opinions describe causation, standard of care, and prognosis. They do not predict verdicts, promise results, or characterize a matter as a "win." Outcome language is the first thing opposing counsel reads back on cross.
Conceding the limits
The strongest opinions name their own boundaries — what the records do not show, what an examination could not establish. A physician who concedes limits is more credible, not less.
Same author, start to finish
When the physician who screened the matter is the one who later testifies, there is no drift between the early read and the sworn opinion. Continuity is itself a defensibility feature.
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