Your law firm represents the Defendant in a Texas state court personal injury lawsuit. Your attorney has met with a nurse practitioner who has found inconsistencies about the injuries claimed by Plaintiff. Your attorney wishes to have the Plaintiff examined by an independent doctor. You have contacted the opposing side's paralegal requesting this examination and they have refused to allow it.

Explain what a party must prove to the Court in order to compel a Plaintiff to submit to an Independent Medical Examination.