NEUROPSYCHOLOGISTS

Personal injury testimony preparation
for neuropsychologists

TBI litigation produces some of the most technically sophisticated cross-examination in civil law. Defense counsel will challenge your validity indicators, your causation opinion, and your base rates. ForensicPrep prepares you for every line of attack.

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Live simulation, TOMM validity cross-examination
ATY
Dr. Williams, you administered the TOMM to my client and she passed. Does passing the TOMM rule out symptom exaggeration?
YOU
No single measure rules out exaggeration entirely. The TOMM is sensitive to frank malingering but has lower sensitivity to symptom magnification or inconsistent effort.
ATY
So passing the TOMM is entirely consistent with someone who is exaggerating their symptoms — just not outright fabricating them?
YOU
That's technically accurate, though my conclusions were based on the full validity profile across multiple indicators, not the TOMM alone.
ATY
Let's talk about that profile. You administered six embedded validity indicators. Three fell below the recommended cutoff. Isn't below-chance performance on a forced-choice measure the definition of intentional failure?
YOU
Below-chance performance is one indicator of suboptimal effort, yes. However, I interpreted the full pattern of findings in context, including base rates for below-chance performance in genuine TBI populations.
ATY
What is that base rate? Specifically.
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What you'll face

Six attack vectors in neuropsychology testimony

01

Validity indicator specificity

Opposing counsel will argue that below-chance performance proves malingering. You need to know the sensitivity, specificity, and base rates for every PVT you administered.

02

TOMM limitations

The TOMM is sensitive to frank malingering but less sensitive to effort variability. Know this distinction. It will be used against you.

03

Causation vs. correlation

Did the injury cause the deficits or did they preexist? Pre-existing conditions and alternative causation are the backbone of defense strategy in TBI cases.

04

Secondary gain context

"Your client stands to receive $4 million if you find deficits. You've acknowledged you were retained by plaintiff's counsel. Isn't that a significant source of bias?"

05

Ecological validity

Lab-based cognitive tests don't always predict real-world function. Defense counsel will argue your battery doesn't demonstrate actual impairment in daily life.

06

Flynn effect

IQ norms become outdated. If you're using WAIS-V norms without addressing the Flynn effect, expect a detailed challenge on whether scores are artificially inflated.

Instrument coverage

Every instrument in your neuropsychological battery

WAIS-VWMS-5TOMMVSVTNV-MSVTWord Memory TestRey 15-ItemD-KEFSTrail MakingNABCVLT-3MoCAMMSE

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