Chain of Possession of Potential Evidence
Hand your investigator or legal assistant a form to record the items you need in showing a chain of possession of potential evidence — and prevent mistakes in getting your evidence before the jury.
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Catch-All Demand for Production
Use a catch-all demand for production as your last discovery demand for production and inspection
Your discovery requests for production and inspection always should end with a catch-all set of demands that forms a wide net, designed to keep you reasonably protected against surprise items.
Plaintiff’s Bodily Injury Deposition or Testimony Checklist
“In every BI deposition and trial, you will want this battle-tested power checklist for questioning the plaintiff regarding his/her bodily injuries.”
Defense Demand for Bodily Injury Damages Disclosure
“A Defense Demand For Disclosure of Damages will make the plaintiff's attorney in personal injury cases spend time preparing information you need. It's politely aggressive.”
This form is for defense attorneys only. And only for BI cases.
It's aggressive, but civil in tone, ethically correct, and follows the federal rule.
At only $10 this is a simple investment with a great return!
Spouse’s Bodily Injury Deposition or Testimony Checklist
Spouse testimony questions outline checklist for personal injury and consortium claim cases
“A trial testimony tool for plaintiff's lawyer. This question outline is designed to have the spouse of the plaintiff describe the bodily injuries in detail — plus discuss loss of consortium.”
The IME Stipulation
Agreement for Medical Examination of Plaintiff
“Don't lose rights — gain advantages — when the defendant asks for a medical examination of your personal injury client.”
If you are a plaintiff's attorney, you probably have run into requests for a physical examination of the plaintiff. Do not just agree to such a request without bargaining for what you will get in return. Even though no court order is involved, you need the protection of many of the items a court would include in its order.
Client Handout for IME
IME Handout — a handout to give your client to prepare them for the medical examination by the defense doctor
Plaintiff’s Request for Admissions Re Medical Expenses
This Plaintiff's Request for Admissions re Medical Expense discovery form will cut out defense games with your trial proof of medical expenses. Use this to make the defense admit any part of your client's medical expenses that the defense cannot affirmatively attack as unreasonable.
Bodily Injury Client Checklist
“Give your personal injury client this BI injury checklist, and save office interview time — plus — get more information.”
Bodily Injury Client Injuries Checklist is a client's testimony injury checklist form you will refer to again and again — with no time spent by you in asking questions to cover all the areas you should ask about!
Bodily Injury Claimant Take-Home Form
“BI Take-Home Form: a time-saver & evidence-builder”
“Have your bodily injury client bring you the items you need for evidence or for your proper development of the BI case. Do it the efficient way, by giving your client a “take-home” form of your requests and advice.”
