Apricots™

An Apricot™ is a work-product privileged report used to assist an attorney in taking a psych doctor’s testimony. An Apricot™ describes all of the substantial flaws in a psych report in jargon-free, non-technical language. An Apricot™ also provides a list of questions and techniques that get those flaws on the record despite what might be the doctor’s evasive or non-co-operative behavior.


An Apricot™ is used when the attorney decides there is weakness in a psych doctor’s report that needs challenging during a deposition or trial testimony.

Apricots™ are needed by attorneys because they have training in the law and not psychology or psychiatry and cannot be expected to find the substantial flaws in a psych doctor’s report and come up with the questions that will expose them during the doctor’s testimony.


The real purpose of Apricots™ is to teach attorneys how to take depositions from psych doctors and to improve the quality of psych reporting.

The weakest link in every psych report is the doctor’s diagnosis. Those diagnostic criteria are found in the DSM-IV-TR or the DSM-5, whichever manual is mandated by the court’s jurisdiction.

Psychological diagnoses are made after considering as many as five different sets of information: the patient’s life history and their presenting complaints, the doctor’s Mental Status Examination data, the objective psychological testing data, the patient’s medical records and collateral sources of information in the form of interview data collected from the patient’s friends, relatives and co-workers.

An Apricot™ provides information that prevents the doctor from answering questions in an evasive manner.

An Apricot™ provides a list of questions to ask the doctor that will reveal the flaws found in their report.

An Apricot™ contains all the psychological information needed to prepare a brief for the court if the attorney decides that they wish to petition to have the court to throw out the doctor’s report.

Apricots™ can be written in any medical discipline such as orthopedics, neurology and internal medicine, or for that matter in any discipline such as real estate or aeronautics.

Apricots™ pay for themselves in terms of the amount of money saved on spurious payouts.

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