Professional Malpractice (General) Expert Witnesses: 122

David Tilkin is a Litigation Support and Expert Witness specialist with over 40 years of experience in the Securities Industry and over ten years of experience in the Compliance Software Industry. Mr. Tilkin has been providing litigation and expert witness services at varying degrees since 2000 when he left First Union Securities to start Protegent.

The Tilkin Group has been singly involved with litigation support and providing expert witness services since 2008. The efforts of the Tilkin Group have supported both private practice attorneys litigating against the securities industry and supported the efforts of financial service firms in their defense of claims.

Mr. Tilkin currently maintains a Series 65 license and has previously maintained a Series 63, 7, 8, 4 and insurance licenses. He has extensive training in the securities industry as a broker, manager and regional director. He has leveraged his intensive background in all aspects of broker-dealer operations, has been retained in over 200 cases, and testified in 85 cases around issues of suitability, supervision, and raiding and sales practices.

David Tilkin has published numerous articles on the issues of suitability, supervision and financial services software. He offers substantive, compelling opinions to support effective legal strategy in the following areas:

Arbitration Failure to Supervise Financial Services Breach of Fiduciary Duty Unauthorized Trading Authentication, Authorization & Accounting Churning

FINRA JAMS Misrepresentations / Omissions NASD Raiding Securities Forensics Analysis Suitability

View The Tilkin Group's Consulting Profile.

Real Estate Brokerage Expert, Manager, Educator

Jane Trust Ryan has over 27 years of experience as a licensed Real Estate professional. She has served as a Real Estate Brokerage Leader, Compliance Officer, and Transaction Manager. Shé has over 20 years of experience training 1,000+ agents in agency, law, contracts, negotiation, disclosure, compliance, and other real estate-related topics across various brokerage models. 

Ms. Trust Ryan is currently licensed as a Broker in NY, NJ, and PA, with past licenses in MD, DC, and VA. She has managed offices with 100+ agents and currently serves as Broker of Record within a network of over 400 agents.

Litigation Support - As an expert witness, Ms. Trust Ryan helps clients navigate the complexities of real estate lawsuits. She specializes in providing clear, actionable insights through thorough research and expert analysis. Her goal is to equip clients with the knowledge and information they need to make informed decisions and achieve the best possible outcomes in their legal matters.

Areas of Expertise

Real Estate Standards of Care Real Estate Brokerage Management Brokerage Agreements Real Estate Contracts Agency Fiduciary Duties Compliance Disclosure

Code of Ethics Due Diligence Real Estate Education Agent Supervision Training & Recruiting Fair Housing Agent Misconduct Broker Malpractice Real Estate Fraud

Bruce Fredrics, International, TI, BSM.h, GA-BC, RGA (EGA), ICEP, GMGA, MPA, SME, CGA, AIC, PPIA, ACA, CACP, CALAc, CCA, CMI, PCLA, LPCS, CMS, HCI/R-C, FSRT, WINDP, AMRT, CPLA, CPLU, CPAU, UCC, CPCUc, CCPc, ACPc, SPPAc, LS-LC (CFLC)

As a U. S. Registered Federal & State Court Certified Subject Matter Expert (SME) for Insurance Appraisal, Claims Processes, and Industry Standards of Practice and Care, practicing since 1986, he is an Exclusive Expert at the most advanced pinnacle. 

A Loss Consultant, Public and Independent Claims Adjuster, Mr. Fredrics is engaged / retained by consumers, insurance companies, and Governments to handle insurance claims settlements and to resolve disputes. His experience includes educating and teaching State Regulators including Directors of Insurance Commissioner Offices, their Attorneys, Plaintiff and Defense Counsel, other Federal Experts, and Professionals, including Managers, Supervisors, and Professionals.

Mr. Fredrics is the Provost of a global and international College where he teaches his unique expertise that he alone has developed. He is also the Chairman of the Board of Governors for a global and international trade association which qualifies Experts under U.S. Congressional Rules.

Litigation Support - Mr. Fredrics has been qualified, approved, and confirmed by Federal & State Judges. As an Expert, he has never been impeached, neither under Daubert nor by any Judge. He has conducted Judge and Jury education in live courtroom testimony, and has testified about 30 (thirty) times as an Expert, none of which has ever been invalidated. Mr. Fredrics assists Attorneys in preparing for trial during litigation in both Federal and State Courts, similar to a Litigation Specialist (LS). He has never lost a case.

Areas of Expertise:

Claims Processes Industry Standards of Practice and Care Man-Made Damage Commercial Property Condominium Construction Defects Claims Disputes Equipment / Mechanical Breakdown Business Interruption Residential Dwelling Manufactured Housing Sinkhole Mold Fire Investigation and Adjustment Environmental / Pollution

Property Liability Catastrophe Losses: Hurricanes, Tornadoes,  Total Losses Product Liability General Liability Professional Liability Harassment Casualty Bodily Injury Fatalities Murder / Homicide, Attempted Murder Weapon Assault Auto Liability / Auto Physical Damage Personal Injury Protection (PIP) Cargo Workers Compensation Liability

View USAE's Business Consultant Profile.

Max Holmes has over 40 years of experience in Finance as a portfolio manager, research analyst, board member, lawyer, NYU Professor and expert witness.

Mr. Homes has been an Adjunct Professor of Finance at the Stern Graduate School of Business at New York University, teaching “Bankruptcy and Reorganization” since 1993.  He has been the Chief Investment Officer / Lead Portfolio Manager for two large hedge funds ($2.7 billion and $5.4 billion of peak AUM) as well as an insurance company portfolio and a mutual fund portfolio.

 The funds invested in credit, capital structure arbitrage, distressed debt, rescue finance, direct lending, specialty finance, event stocks and special situations securities, including long and short positions. The funds invested across the capital structure: bank debt, DIP loans, second lien debt, secured and unsecured bonds, floating rate and fixed rate notes, trade claims, preferred stock, common stock, put and call options and credit default swaps (CDS). Investments were in a variety of businesses, public and private, including startups, venture capital, infrastructure, leveraged buyouts, private equity, turnarounds, restructurings, bankruptcies and liquidations. Direct lending was conducted through a Business Development Company (BDC) ($1 billion assets under management). Mr. Holmes has analyzing thousands of companies and investment opportunities over his career.

Areas of Expertise:

Annuities Antitrust Arbitration Bankruptcy Business Litigation Business Valuation Class Action Contract Disputes Corporate Governance Cryptocurrency and Bitcoin Due Diligence (Investments) Economic Damages Health Insurance Hedge Funds Investment Banking

Investment Management Lending & Risk Management Leveraged Buyouts Lien Enforcement Life Insurance Loan Trading Mediation Mergers and Acquisitions Private Equity Investing Reinsurance Securities / Stock Litigation Securities Arbitration / Mediation Turnaround Management & Investing Wall Street Custom and Practices View More Specialties

Mr. Holmes has been the Chair and CEO of a life, health and annuity insurer and reinsurer and has been an independent director of a large bitcoin mining company. He worked in investment banking, research, trading and capital markets at Drexel Burnham Lambert, Salomon Brothers, NatWest Markets and Royal Bank of Canada. Since 2015, Max Holmes has been a Senior Advisor to American Industrial Partners LLC, a private equity firm with $16 billion of AUM.

Dan W. Wall, BSME, specializes in the fields of Accident Reconstruction, Biomechanics and Motor Vehicle Injury Causation, Human Factors, and Injury Prevention in Motor Vehicle Design. Mr. Wall is fully accredited with ACTAR (Accreditation Commission for Traffic Accident Reconstruction), ACTAR No. 1140.

Dan Wall has conducted scientific and engineering analysis of motor vehicle collisions since 1987 for both plaintiff and the defense in civil and criminal cases. A qualified expert witness since 1987, he has offered litigation support services to insurance companies and attorneys in Arizona, California, Colorado, Tennessee and Louisiana and has testified in both Civil and Federal Courts.

Mr. Wall's past cases have involved commercial vehicle design and analysis, insurance investigations, low speed collisions and injury analysis, motorcycle collisions and rider analysis, vehicle handling and dynamics, seat belt analysis and injury mitigation, tire failures and rollover analysis, general accident reconstruction, and roadway analysis. He has conducted human factor analysis including reaction and perception, environmental effects, and general driver behavior. With a large library and the tools needed to do all types of motor vehicle reconstruction investigations, Mr. Wall is an asset to any team.

Dan Wall currently owns and rides a Harley Davidson Ultra Electra Glide Classic motorcycle and has gone through various levels of motorcycle training. He also has extensive experience as a boat operator and Marine Instructor.

For more information, visit www.wallaccidentreconstruction.com

Also view Dan Wall's article in Attorney At Law Magazine at http://attorneyatlawmagazine.com/phoenix/2014/01/17/accident-reconstruction-expert-dan-wall/

Areas of Expertise:

Mechanical Engineering Biomechanics Human Factors Accident Reconstruction Failure Analysis Forensic Investigation Motor Vehicle Design Dynamics and Handling Motorcycles Commercial Vehicles Rollovers Signage

Conspicuity Low Speed Collisions Marine Safety Bicycles Slip and Fall Accidents Pedestrians Accidents Tire Failure Seat Belt Issues Road Defects Off Road Driving Accidents Construction Zones Product Liability

View Dan Wall's Consulting Profile.

Jeffrey Phillip Weinstein, AIA, a California licensed Architect since 1982, with Masters Degree in Real Estate Development from USC, has been involved in the development, design and construction of office buildings, high-rise condominiums, multi-family residential podium-type projects, retail, neighborhood shopping centers and regional malls, hotels and resorts, hospitals, and schools (K-12 and University).

Expert in real estate development, government approvals, entitlements & permits, architect's standard of care, construction management, claims & defects, A/E/C agreements. Expertise includes building envelope & water intrusion, zoning & building codes, errors/omissions, destructive testing & repair, schools (DSA), hospitals (OSHPD), condominiums, commercial/retail/mixed-use projects, high-rise structures, hotels & resorts. Previous employers include Nadel and Callison Architects, Tishman Construction, Trammel Crow Company, Kaiser Permanente, and California State University.

Professional Licenses / Certifications / Affiliations:

• California Registered Architect, License #12822
• Member, American Institute of Architects, Urban Land Institute, Construction Specification Institute, and Society for Marketing Professional Services
• Member, North Santa Barbara County Board of Architectural Review

Litigation Support: Jeffrey Weinstein has been retained as an expert witness as Owner's Representative, Construction Manager, Contract Administrator, Project Manager and Architect by Developers, Builders, Institutional Owners (Hospitals & Schools), Municipalities, and Corporate Clients. Mr. Weinstein provides professional Architectural and Construction Expert Witness opinion, testimony and services on matters, such as:

Architectural Forensic Architectural Construction Management Building Code Requirements Construction Industry Standards Professional Standard of Care Design Defects, Errors & Omissions

Construction Defects & Failures Architectural Practice & Peer Review Construction Claim Evaluation Change Order Analysis & Cost Overruns Zoning Entitlements, Land-Use, and Permitting Project Delivery - Fast-Track, Design-Build, GMP Design & Construction Accident Claims

View Jeffrey P. Weinstein's Consulting Profile.

Clinton F. Merrill, Jr., MD, has over 35 years of experience in clinical Internal Medicine and 28 years of experience in Medical Oncology and Hematology. Dr. Merrill is experienced in the diagnosis and treatment of all solid tumors as well as the full range of hematologic malignancies. He has special expertise in benign hematology including: anemias, low blood cell counts, iron overload disorders, bleeding and clotting disorders. Litigation Support - Dr. Merrill offers expert witness services to counsel representing Plaintiff and Defendant. His services include medical record review, written reports, depositions, and trial testimony. Dr. Merrill takes pride in providing thorough record review, meticulously researched reports reflecting unbiased opinions, and excellent communication skills with the ability to make the complex understandable. Areas of Expertise:

Breast Cancer Colon Cancer Lung Cancer Tumors Leukemias Lymphomas

Myeloma Myeloproliferative Disorders Myelodysplastic Syndromes Benign Hematology Anemia Bleeding and Clotting Disorders

James M. Wheeler, MD, MPH, JD, magna cum laude in Biology / Psychology from Harvard, is an OB/GYN trained at Baylor, with subspecialty training in Reproductive Endocrinology / Infertility at Yale. He is also a graduate of the Robert Wood Johnson Clinical Scholars Program at Yale, focusing upon clinical epidemiology and biostatistics and health policy. He also earned his MPH at Yale majoring in Biostatistics, minoring in Maternal/Child Health. He graduated from the University of Houston Law Center with a JD in 2005, and was invited to join the Health Law division there. He has completed ADR training, having completed training programs separately in mediation, and arbitration.

Dr. Wheeler is a former national officer of the American College of Obstetricians and Gynecologists (ACOG), and served on several of their health policy committees including the Health Care Commission and the Hysterectomy Committee. He has published over 40 peer-reviewed papers on a wide array of topics in ob/gyn, with a particular emphasis on methodology. He has given over 200 invited lectures to ob/gyns, reproductive endocrinologists, radiologists, midwives, nurses, surgical technologists, law students et al. He sees himself first and foremost as a caregiver, and second to only that, as a teacher.

Dr. Wheeler has consulted in several hundred medicolegal matters for over 20 years, mostly in ob/gyn, but including family practice, internal medicine and several of its subspecialties, general surgery and several of its subspecialties, and dermatology. He has been a testifying expert before the FDA for drugs and devices, and has testified before U.S. Congressional staffers on health policy issues. He reviews for attorneys from both plaintiff and defense bars, as well as insurance companies (e.g. Pro-Assurance), and health plans (e.g. Harvard Community Health Plan). He has helped with Board of Medicine reviews, and constructing/defending class action suits. The combination of his training in medicine, basic and clinical research, clinical epidemiology, biostatistics and law make him a uniquely qualified person to review the complex issues of medicolegal cases.

Dr. Wheeler is a qualified first-reviewer, and a convincing expert during testimony. He has never been excused from a case as insufficiently expert.

Areas of expertise:

Gynecologic surgery Forceps / Vacuum Uses/ Complications Fetal Stress vs. Distress Cesarean vs. Vaginal Birth Shoulder Dystocia Pregnancy induced Hypertension / HELLP Syndrome Hysterectomy: Indications and Complications

Preterm Labor Incompetent Cervix Endometriosis Pelvic Adhesions Leiomyomata Uteri Infertility Advanced Reproductive Technology (IVF)

Expert witness testimony for complex litigation involving damage analyses of lost profits, reasonable royalties, lost earnings, and lost value of business, forensic accounting, fraud investigation, investigative analysis of liability, marital dissolution, and tax planning and preparation. Excellent communicators with extensive testimony experience. Prior Big Four accountants. Specialties include: accounting, antitrust, breach of contract, business interruption, business dissolution, construction defects, delays and cost overruns, fraud investigation, asset tracing, intellectual property including patent, trademark and copyright infringement and trade secrets, malpractice, marital dissolution, personal injury and employment litigation, product liability, real estate, securities, spousal support, taxation, unfair advertising, unfair competition, valuation of businesses, and wrongful termination.

Experts:

Business Litigation and Valuation Barbara Luna, PhD, CPA, CFE, ASA,     CVA, ABV, CGREA, CCRA, CREA John Luna, JD/MBA, CPA, ABV, CFF Dean Atkinson, CPA, CFE, ABV, CAC, CFF David Turner, CPA, ABV, CFF Drew Hunt, MBA, CPA, ASA

Personal Injury / Employment Litigation Barbara Luna, PhD, CPA, CFE, ASA,     CVA, ABV, CGREA, CCRA, CREA Venita McMorris, MA

Dr. Barbara Luna is the partner in charge of the commercial litigation department of White Zuckerman. She has been providing Forensic Accounting, Economic Damages, Valuation, and Expert Witness Services for the past 30 years and has testified in court over 450 times. She has a PhD in Applied Mathematics from Harvard University with application to Physics and Finance and a BA in Physics from Wellesley College. Barbara is a Certified Public Accountant, a Certified Fraud Examiner, an Accredited Senior Appraiser in Business Valuation, a Certified Valuation Analyst, Accredited in Business Valuation, a Certified General Real Estate Appraiser, and a Certified Financial Forensic. She previously was a partner with Coopers & Lybrand and has taught working capital management, business finance, forensic accounting and intermediate accounting at UCLA Graduate School of Management, California State University at Northridge and Pepperdine University.

John Luna is a partner in the commercial litigation practice of White Zuckerman. He analyzes Financial, Accounting, Economic Damages, Business, Real Estate and Valuation issues and testifies as an expert witness on his findings. He has been an investment banker with Macquarie Capital, GCA Savian and Lazard. John has a JD from UCLA School of Law (Order of the Coif), an MBA from UCLA Anderson School of Management (Edward W. Carter Fellow), and an AB in Engineering Sciences from Harvard University. He is a Certified Public Accountant, Accredited in Business Valuation, a Certified Financial Forensic and a member of the California Bar.

Dean Atkinson is a partner in the commercial litigation practice of White Zuckerman. He has testified as an expert witness in Commercial Litigation and Family Law Matters and has been involved in Resolution and Settlement Negotiations since 1987. He holds credentials from the AICPA as a Certified Public Accountant, Accredited in Business Valuation and Certified Financial Forensics and from the Association of Certified Fraud Examiners. Dean is experienced and has qualified as an expert in business valuation, business litigation and family law matters.

Venita McMorris is a partner and an Economist in the Personal Injury and Employment practice of White Zuckerman. She has been providing economic damages and expert witness services for over 20 years and has testified extensively in court. She has a Master of Arts degree in Economics from California State University, Fullerton and a Bachelor of Arts degree from San Diego State University. She previously was a manager with Coopers & Lybrand and an economist with a medical malpractice trust in Southern California. Venita has taught macroeconomics and microeconomics to college students at Pasadena City College as a full-time tenured instructor and at Glendale Community College as a part-time instructor.

Los Angeles 15490 Ventura Boulevard, Suite 300 Sherman Oaks, CA 91403 Phone: (866) 981-4266 or (818) 981-4226 Fax: (818) 981-4278 Email: expert@wzwlh.com Website: www.wzwlh.com

Orange County 4 Park Plaza, Suite 200 Irvine, CA 92614 Phone: (949) 219-9816 Fax: (949) 219-9095 Email: expert@wzwlh.com Website: www.wzwlh.com

Jonathan Wiesen, MD received training in Pulmonary and Critical Care Medicine with a special focus on Medical Ethics.

Dr. Wiesen is currently a Pulmonary and Intensive Care Attending Physician at Community Intensivists where his duties include general clinical care and workflow organization and protocol authorship. He also serves as a Medical Technology Analyst at OurCrowd where he is responsible for the Scientific and financial assessment of medical technology start up companies and provides multi-disciplinary interactions for assessments and investments.

Dr. Wiesen has extensive academic experience with over 75 publications, including first authorship on over a dozen full length manuscripts. He has been honored with the Teaching Excellence Award from the Cleveland Clinic, a non-profit academic medical center, which provides clinical and hospital care and leads in research, education, and health information. He also received the Best Abstract Award, Critical Care session, at the ACCP CHEST annual conference in 2014.

Litigation Support - Dr. Wiesen provides expert witness services to attorneys representing plaintiff and defendant. His services include medical record review, written reports, depositions, and trial testimony as needed.

Areas of Expertise:

Cardio-Pulmonary Hemodynamics Respiratory Physiology End of Life Sepsis / Septic Shock Pneumonia COPD Asthma Life Support

Mechanical Ventilation Smoking Related Diseases Interstitial Lung Disease Pulmonary Hypertension Lung Transplantation Biomedical Ethics Conflict Resolution Triage

Jeffrey M. Wilder, DC, DABCO, FICC, has over 42 years of experience as a Chiropractor, and 38 years in private Chiropractic Practice. Engaged in private family-oriented practice as a chiropractor in Madison, Wisconsin since 1981, Dr. Wilder has completed a post-doctorate program in chiropractic orthopedics from National College and is a Board Certified Chiropractic Neuromusculoskeletal Specialist, a Diplomate of the American Board of Chiropractic Orthopedists, and a Fellow of the International Academy of Neuromuscular Medicine. This program is successfully completed by less than 1% of the nation’s chiropractors. 

Dr. Wilder has also been certified by the American Chiropractic Association Sports Council as a Certified Chiropractic Sports Physician, a 120-hour certificate program dealing with sports training, and the treatment and prevention of sports injuries. He has completed state requirements in physiological therapeutics, surface EMG, and clinical nutrition, among others.

Dr. Wilder has also served as an officer on the Board of Directors for the Congress of Chiropractic State Associations, which commissioned the chiropractic profession’s first nationwide clinical protocol, known as, Guidelines for Chiropractic Quality Assurance and Practice Parameters: Proceedings of the Mercy Center Consensus Conference, 1993, Aspen Publishers, Gaithersburg, MD.  

A Past President of the 1,800 member Wisconsin Chiropractic Association, Dr. Wilder had one of the longest terms (6 years) in the 100+ year history of the organization. He currently serves as the representative for the chiropractic profession to the Wisconsin Medicare Carrier Advisory Commission.  He has also been a consulting expert to the state of Wisconsin's Worker's Compensation Division for the past 22 years.

Dr. Wilder has taught extensively to chiropractors around the country, providing continuing education. He has been a frequent spokesperson for chiropractic in the press, television and radio, including regular appearances on statewide Wisconsin Public Radio.

Litigation Support: Dr. Wilder has extensive experience over the past 29  years as a court-recognized Chiropractic Expert throughout the United States and Puerto Rico. Dr. Wilder has served as an expert in over 300 cases of alleged Chiropractic Malpractice, Motor Vehicle Accidents and Fraud Review.   He has reviewed and testified in court for both plaintiffs and defendants in cases involving chiropractic treatment, including claims of:

Chiropractic Standard of Care Clinical Malpractice Negligence Sexual Boundary Issues License Issues Disciplinary Actions

Fraud Review Informed Consent Documentation Worker's Compensation Diagnosis / Evaluation Management

Merrill S. Wise, MD, is Board-Certified in Psychiatry and Neurology with special qualifications in Child Neurology, and he is certified by the American Board of Sleep Medicine. Involved in the full-time practice of sleep medicine, Dr. Wise has evaluated and managed the full range of Sleep Disorders since 1991.

Dr. Wise evaluates children, adolescents, and adults with the full range of sleep problems and disorders. He is involved with supervision and interpretation of polysomnography (sleep studies), Multiple Sleep Latency Tests (MSLT), Maintenance of Wakefulness Tests (MWT), and integration of these findings with the clinical history in order to develop a diagnosis and treatment plan.

Because of the population served in Memphis, Dr. Wise evaluates a large number of pilots (FedEx world hub), air traffic controllers, commercial drivers and barge pilots, rail engineers, and shift workers. He is experienced in the treatment of obstructive sleep apnea (OSA), narcolepsy, and other disorders of excessive sleepiness, insomnia, circadian rhythm sleep disorders, restless legs syndrome, and parasomnias.  This expertise and experience allows him to analyse and provide valuable opinions on a wide range of sleep-related legal issues.

Litigation Support - Dr. Wise has reviewed a wide variety of cases involving both neurology and sleep medicine for greater than 20 years including report generation, testimony at deposition, and at trial. He has served on numerous national task forces and committees, as well as the Board of Directors of the American Academy of Sleep Medicine (AASM). These experiences have exposed him to the full range of sleep disorders, as well as healthcare systems, best practices and evidence-based standards of care, policies, and the legal aspects of sleep problems and disorders. 

Special Interest and Expertise:  

• Individuals with Excessive Daytime Sleepiness
• Downstream Effects of Sleepiness on
  • Cognitive Function
  • Driving
  • Safety
  • Work
  • Behavioral Regulation

Fred Beck, DC, with over 45 years in practice, performs Chiropractic Medical Malpractice Reviews, Expert Witness, IME's (1500+), Peer Reviews (7500+). Dr. Beck allows videotaping and observers in room if requested by patient / claimant. Zero IME's and Peer Reviews have gone to deposition or court. Licensed in New York & Florida. Past Public Relations Director of Broward County Chiropractic Society. Chiropractor of the Year (Broward County). Writer, lecturer, ringside physician, Pharm patent etc.

Jon-Eric Kronvall has over 35 years of experience in the Financial Services profession. He is the Founder of Esoteric Advisors, an expert consulting firm that specializes in unique and specialized areas of knowledge in financial services. Mr. Kronvall is also the Founder and Chief Compliance Officer at Wealth Innovation, a Registered Investment Advisory Firm.

Expertise: Expert Witness, Trusts, Estates, Fiduciary, Securities, Investments, Banking, Lending, Real Estate

Marilyn McCullum, BSN, RN, CEN, is a certified Emergency Nurse with peer-reviewed publications, speaking engagements, and testifying experience. She specializes in emergency nursing, general nursing care, medical documentation bias, and medical products as an end-user. She stays active in her clinical position and teaches her peers about documentation and triage.

Ms. McCullum's expert opinions are unbiased, neutral, and fact-based, following the national Standard of Care.