Analyze Complaint and allegations contained therein and initial correspondence in claim file from adjuster as to plaintiff, and initiate Case Analysis as to treating physicians; hospitalization; employment history and collateral sources.
Analyze and summarize medical records contained in Claim File from _____, identifying dates of treatment, services rendered, assessments of Plaintiff and medications prescribed, and incorporate such summary into the Medical Chronology portion of the Case Analysis to assist in the defense of this claim.
Analyze medical records received pursuant to Defendant's Subpoena Duces Tecum Without Deposition directed to: (NAMES), to catalog and sort all billing records; patient forms; history and injury questionnaires; progress notes; diagnostic and laboratory tests; and prescription records in anticipation of preparing Medical Records Notebooks, to be used for attorney reference during the upcoming mediation and depositions.
Review/analyze for accuracy and content: pleading to the Court requesting Plaintiff to comply with Defendant’s (DISCOVERY), propounded upon Plaintiff on (DATE) and proposed Order on Defendant’s pleading to the Court requesting Plaintiff to comply with Defendant’s (DISCOVERY), propounded upon Plaintiff on (DATE).
Review and analyze plaintiff's response to defendant's request for production of documents, and identify any medical providers, employers and insurance companies not previously listed, in further defense of claim.
Prepare detailed and comprehensive response to Plaintiff’s Interrogatories to Defendant dated (DATE), to include (ITEMS REQUESTED IN ROGGS), and our objections to those requests which invade the attorney/client and/or work product privilege, vague and overburdensome, and providing responses that are relevant, and reasonably calculated to lead to the discovery of admissible evidence.
Investigation regarding Plaintiff's medical providers, insurance providers, and employers in anticipation of preparing Defendant's Subpoenas Duces Tecum Without Deposition for records of the Plaintiff.
Evaluate present posture of subject litigation with a specific focus on status of damages for assessment and follow-up regarding the development of our discovery strategy as it pertains to our mitigation of damages claimed by the Plaintiff.
Analyze Notice of Production from Non-Party and proposed Subpoenas Duces Tecum Without Deposition filed by (NAME) issued to the following providers, to identify all providers not previously disclosed, in anticipation of preparing Request for Production of Documents for records received pursuant to said Subpoenas.
Prepare correspondence to Plaintiff’s counsel regarding pleading to the Court for HIPAA Qualified Protective Order and Order to Disclose Protected Health Information, as to Plaintiff, to protect all parties, their attorneys and experts from any potential HIPAA violations for disclosure to issues related to the pending litigation.
Review, analyze and summarize Plaintiff's medical records provided by (NAME) pursuant to Defendant’s Subpoena Duces Tecum Without Deposition, to identify discharge notes and follow-up recommendations, and to incorporate such summary of treatments into Defendant's Medical Chronology of Plaintiff for attorney reference during continued defense of this claim.
Summarize contents of claim file for purposes of inputting relevant information into Case Analysis/Medical Chronology, developing a substantive outline with specific emphasis on identifying witnesses, insurance companies, medical and employment providers, in preparation for preparing non-party production request.
Conference with _____ with regard to request for conflict check, request for curriculum vitae and fee table in assistance of counsel in vetting for consideration of medical records review and/or compulsory medical evaluation of Plaintiff, in compliance with Court's Order setting trial and disclosure deadlines therein.
Review, analyze and summarize Plaintiff’s Answers/Responses to (NAME OF DISCOVERY), to identify Plaintiff’s recollection of the subject incident, any witnesses Plaintiff recalled at the subject incident; details of the Plaintiff’s attire on the day of the subject incident, and incorporate such summary into the Case Analysis for attorney reference during the defense of this claim.
Analyze all available medical records and documents produced to date, pursuant to Subpoena Duces Tecum Without Deposition to non-parties, to identify witnesses to testify at trial, in anticipation of preparing Defendant's Witness List.
Analyze all pleadings generated by the parties, deposition transcripts, summaries, available interrogatory responses of plaintiff, all discovery responses of plaintiff, and all expert witness reports, in identifying and itemizing liability witnesses and expert witnesses who will testify at trial, and in identifying and itemizing exhibits to be produced at trial.
Analyze file for information re subject accident to insure proper party names in preparation for drafting of defendants Proposal for Settlement to plaintiff, in the amount of $_____________ as to defendant, _________ only.
Review account statements and sales of stock; determine issues with respect to alternate valuation and date of death valuation. Review real estate sales contract and closing statements.