expert-omissions-analysis
Analyzes expert witness reports against complete medical record sets to identify omissions, bias patterns, and methodology gaps. Generates impeachment-ready reports with pin-cited findings and strategic recommendations. Triggers when the user needs to review opposing expert reports, prepare cross-examination, support Daubert/Frye motions, or retain rebuttal experts in personal injury or medical malpractice litigation.
Best use case
expert-omissions-analysis is best used when you need a repeatable AI agent workflow instead of a one-off prompt.
Analyzes expert witness reports against complete medical record sets to identify omissions, bias patterns, and methodology gaps. Generates impeachment-ready reports with pin-cited findings and strategic recommendations. Triggers when the user needs to review opposing expert reports, prepare cross-examination, support Daubert/Frye motions, or retain rebuttal experts in personal injury or medical malpractice litigation.
Teams using expert-omissions-analysis should expect a more consistent output, faster repeated execution, less prompt rewriting.
When to use this skill
- You want a reusable workflow that can be run more than once with consistent structure.
When not to use this skill
- You only need a quick one-off answer and do not need a reusable workflow.
- You cannot install or maintain the underlying files, dependencies, or repository context.
Installation
Claude Code / Cursor / Codex
Manual Installation
- Download SKILL.md from GitHub
- Place it in
.claude/skills/expert-omissions-analysis/SKILL.mdinside your project - Restart your AI agent — it will auto-discover the skill
How expert-omissions-analysis Compares
| Feature / Agent | expert-omissions-analysis | Standard Approach |
|---|---|---|
| Platform Support | Not specified | Limited / Varies |
| Context Awareness | High | Baseline |
| Installation Complexity | Unknown | N/A |
Frequently Asked Questions
What does this skill do?
Analyzes expert witness reports against complete medical record sets to identify omissions, bias patterns, and methodology gaps. Generates impeachment-ready reports with pin-cited findings and strategic recommendations. Triggers when the user needs to review opposing expert reports, prepare cross-examination, support Daubert/Frye motions, or retain rebuttal experts in personal injury or medical malpractice litigation.
Where can I find the source code?
You can find the source code on GitHub using the link provided at the top of the page.
SKILL.md Source
# Expert Omissions Analysis Cross-references expert materials against the full medical record set to surface omitted records, classify their impact, and produce a structured impeachment report. ## Prerequisites - **Complete medical record set** — Bates-stamped or indexed, all discovery-produced records - **Expert materials** — report(s), deposition transcript(s), CV, supplemental declarations - **Expert's materials-reviewed list** — extracted from report or deposition - **Case chronology** — treatment timeline, injuries, key medical events ## Workflow ### 1. Inventory and Cross-Reference Build a comparison matrix with columns: Record ID/Bates range, date of service, provider/facility, record type, cited by expert (Yes/No/Partial), and expert cite location (report page or depo page:line). Flag every record where cited = No or Partial. ### 2. Classify Omissions Assign priority to each flagged record: | Priority | Criteria | |---|---| | **Critical** | Contradicts opinion, shows alternative causation, or reveals undisclosed pre-existing condition | | **High** | Fills chronology gap or documents unaddressed treatment decisions | | **Moderate** | Qualifies or weakens conclusions | | **Low** | Cumulative or unlikely to affect opinion foundation | ### 3. Evaluate Methodology Assess the expert's review process: - Did the expert provide a complete materials-reviewed list? - Does the expert's chronology match the actual medical timeline? - Are factual assertions contradicted by records the expert claims to have reviewed? - Did the expert acknowledge and explain gaps? - Does the methodology satisfy Daubert/Frye reliability factors? ### 4. Identify Bias Patterns Flag systematic omission patterns: - Omissions cluster around records supporting opposing theory - Pre-existing conditions consistently excluded - Unfavorable imaging/labs ignored while favorable ones cited - Selective quotation (partial citation) - Temporal gaps obscuring intervening causes ### 5. Generate Report Structure output as: **I. Executive Summary** — total records, count not cited, critical/high omission count, key finding (1–2 sentences) **II. Omissions Table** — matrix from Step 1 filtered to omitted records, sorted by priority **III. Critical Omissions Detail** — for each Critical/High item: omitted record ID, content summary, expert's statement (quote + cite), impact on opinion foundation **IV. Methodology Deficiencies** — Step 3 findings with supporting citations **V. Bias Pattern Analysis** — Step 4 patterns with statistical support where available **VI. Strategic Recommendations** — cross-examination questions (numbered, pin-cited), Daubert/Frye challenge points, rebuttal expert focus areas, deposition follow-up topics if discovery is ongoing ## Pitfalls and Checks - **Pin-cite everything** — every assertion references a Bates number, depo page:line, or report page - **Do not overstate minor gaps** — flag low-priority items but distinguish them from genuine impeachment material - **Note defensible omissions** — record may be cumulative or irrelevant to the specific opinion rendered - **Daubert factors**: testability, peer review, error rate, general acceptance, fit to facts [VERIFY: *Daubert v. Merrell Dow Pharmaceuticals*, 509 U.S. 579 (1993)] - **Frye jurisdictions**: standard is general acceptance only; flag when applicable [VERIFY: *Frye v. United States*, 293 F. 1013 (D.C. Cir. 1923)] - **Adapt for either side** — plaintiff (challenging defense IME expert) or defense (challenging treating physician or plaintiff's retained expert) - **Do not render medical opinions** — identify what records say and what the expert missed, not whether the medical conclusion is correct
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