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Letter of instruction to a psychiatric expert witness

A letter of instruction to a psychiatric expert witness should do four things: identify the party represented and the forum, state the questions on which opinion is sought, enclose the records the expert needs to answer them, and fix the timetable. A letter that does all four allows the report to be prepared without a round of clarifying correspondence.

What to include

What the letter should contain

  • The examinee's full name, date of birth and current address.
  • The party you represent and the court, tribunal or regulator involved.
  • A short factual background to the events complained of.
  • Numbered questions, each capable of a direct answer.
  • A list of the records enclosed and those still awaited.
  • The date the report is required and any fixed diet of proof.
  • Confirmation of who is responsible for the fee.
  • The names of all parties, so the conflict check can be completed.

Questions framed in Scottish terms — pursuer and defender, proof, Court of Session or sheriff court — avoid the ambiguity that arises when an English precedent is adapted.

Model letter

Model letter of instruction

Copy the text below onto your firm's letterhead and adapt the bracketed fields. The questions at paragraph 3 cover the usual civil personal injury instruction; delete or add as the case requires.

Model letter of instruction

[Firm letterhead]

Dr Yameen Qureshi
Insight Medicolegal
Centrum Business Park
38 Queen Street
Glasgow G1 3DX

Dear Dr Qureshi

LETTER OF INSTRUCTION — [Examinee full name], date of birth [DD/MM/YYYY]
Our reference: [ref]  ·  Court/tribunal reference: [ref]

1. Party represented
   We act for the [pursuer / defender / respondent / appellant] in this matter.
   The action is [raised in / to be raised in] [Court of Session / Sheriff Court
   at [place] / Employment Tribunal].

2. Background
   [Two or three sentences: the incident or events complained of, the date, and
   the psychiatric injury or issue said to arise.]

3. Questions on which opinion is sought
   a. Whether the examinee suffers, or has suffered, from a psychiatric disorder,
      and if so the diagnosis by reference to ICD-11 or DSM-5.
   b. Whether that disorder was caused or materially contributed to by the events
      described, and the position had those events not occurred.
   c. The effect of the disorder on daily living, relationships, and capacity for
      work or study.
   d. Treatment received to date, treatment recommended, and the likely cost and
      duration of that treatment.
   e. Prognosis, including the expected date of recovery or the extent of any
      permanent impairment.
   f. Any pre-existing vulnerability, prior psychiatric history, or unrelated
      factors bearing on the above.
   g. [Any further question specific to this case.]

4. Enclosures
   [List the records enclosed — see checklist. Confirm the expected date of any
   records still outstanding.]

5. Timetable
   A report is required by [date]. The proof/hearing is fixed for [date, if known].
   Please confirm availability for that diet.

6. Terms
   Please confirm your fee for this report and your availability. We confirm that
   fees will be met by this firm.

7. Conflict
   The parties are [names]. Please confirm you have had no previous treating or
   reporting involvement with any of them.

Appointment arrangements may be made directly with the examinee, whose contact
details are: [telephone] / [email] / [address]. [Note any interpreter, mobility,
communication or safeguarding requirement.]

Yours faithfully

[Name]
[Firm] · [Telephone] · [Email]

Enclosures

Checklist of documents to enclose

GP records
Full set, including consultations pre-dating the index events.
Hospital and A&E records
Admissions, discharge letters and psychiatric contacts.
Community mental health records
CPN notes, psychology records and any addiction service involvement.
Occupational health file
Referrals, reports and any ill-health retirement papers.
Previous expert reports
Including reports for the opposing party, where available.
Pleadings
Summons or initial writ, defences and any adjustments.
Schedule of damages
Together with any counter-schedule.
Wage and employment evidence
Payslips, absence records and terms of employment.
Witness statements
Where they bear on presentation, function or the index events.
Police or incident reports
Where the events are disputed or involve alleged assault.

Where records are incomplete, the report can still be prepared and an addendum issued once the outstanding material arrives. That approach is set out under reports.

Sending

Sending the instruction

Letters of instruction and records may be sent to instructions@insightmedicolegal.co.uk or by post to Centrum Business Park, 38 Queen Street, Glasgow, G1 3DX. Bulk records are best sent by secure file transfer; a link is accepted. Receipt is acknowledged, with the conflict position and an indicative timetable, before work begins. The full process is set out under instructing Dr Qureshi.