If you are a paralegal supporting accident attorneys, there may come a time when you are asked to interview a potential client.

You will want to obtain pertinent information to give the attorney you support the best opportunity to analyze the case, and make a decision about representation.

Here are 33 questions to ask the potential client about their auto, motorcycle or pedestrian accident:

Accident Details and Liability

1. What is your name, address, telephone number and email address?
2. When/where/how did the accident occur?
3. Who do you believe caused the accident?
4. Was the accident reported to the police? If so, who responded to the scene?
5. Do you have a copy of the police report? If not, do you have the report number?
6. Do you have the name of the other driver(s)?
7. Did the other driver receive a citation from the police? If so, for what?
8. Did you receive a citation from the police? If so, for what?
9. Were there any witnesses to the accident?
10. Were there any passengers in your vehicle? Passengers in the other driver’s vehicle?

Property Damage, Insurance and Claim Information

11. Describe your vehicle’s property damage. Moderate? Severe?
12. Describe the other driver’s property damage. Moderate? Severe?
13. Do you have photos of the scene and/or damage to the vehicles?
14. Were any vehicles towed from the accident scene?
15. Have you received an estimate for your vehicle’s property damage?
16. Who performed the estimate? Was your vehicle totaled or can it be repaired?
17. Has your property damage claim been resolved?
18. Identify your auto insurance company and policy number.
19. What type of insurance coverage do you have? Comp/collision? Med-pay? Uninsured/underinsured motorist?
20. Have you reported the accident to your insurance company?
21. Who is the adjuster assigned to your claim? What is the claim number?
22. Identify the other driver’s insurance company, policy and claim numbers.
23. Have you spoken with any representatives of the other driver’s insurance company? If so, identify the person.
24. Have you given recorded (or written) statements to either insurance company?

Injuries and Medical Treatment

25. Did you sustain injuries due to the accident? Describe your injuries in detail.
26. Do you have photos of your injuries?
27. Were you transported from the scene by an ambulance? Were you treated in the emergency room? If so, identify the hospital and describe the length of your stay.
28. What was the ER doctor’s diagnosis? Were you prescribed any medications, splints, crutches, etc? Were you advised to follow up with another doctor?
29. Identify all doctors that have treated you since the accident. Include your primary care physician, physical therapist, hospitals, radiology and other facilities.
30. Are your injuries resolved? Have you been released from medical care?

Medical Bills, Lost Wages and Out-of-Pocket Expenses

31. Have you received any billing statements from medical providers? Have any of your medical bills been paid by Medicaid or Medicare, private insurance, med pay coverage, etc?
32. Have you incurred out-of-pocket expenses for prescriptions, treatment, rental cars or anything else related to the accident?
33. Have you missed any time from work? If so, how many days, weeks or months have you missed?

This is only a partial list of questions you can use to interview potential clients in auto, motorcycle and pedestrian accident cases – but hopefully enough to get you started.

What have I left out? Feel free to share additional questions in the comments below.

This article is part of the “How To” blog series in which I offer practical tips that legal professionals can use to support attorneys before, during and after litigation. Subscribe to get updates so you won’t miss the next article in the series!

Image credit:  jchinique

Earlier in the blog series, we discussed tips for requesting, organizing and summarizing records in personal injury cases.

Today, we will cover how to Bates number those documents. This information can be applied to all types of records (not just medical) in litigation matters.

What is Bates Numbering?

Bates numbering – also known as bates stamping – is when you add numbers to label, identify and index documents. You can Bates number a single document or an entire set. In litigation, this may include medical, employment and insurance records, as well as legal pleadings and exhibits that are pertinent to the client’s case.

You can later reference the Bates numbers in chronologies, summaries and indexes you prepare for the case.

How to Bates Number Documents?

Gone are the days of relying on hand-held Bates stamps and bulky numbering machines – which was the case when I took my first job as a legal professional.

With today’s technology, you can Bates stamp documents in a couple of minutes with programs like CutePDF Professional (my choice!) and Adobe Acrobat.

Here are step-by-step instructions for using CutePDF to add Bates numbers to documents:

1.    First, make sure the document is in PDF format. (If not, you will need to convert the document to PDF first.)

2.    Open the CutePDF program.

3.    Open the document that you want to Bates number.

4.    Select “Header and Footer” in the menu bar.

5.    Choose a location to insert the Bates number. Generally, it is added to the right footer area of the document. However, CutePDF gives you an option to add it to the left or middle footer areas as well as the header area.

6.    Use the tag function (<b>) for chronological numbering of the pages, and be sure to set the length of the Bates number to 5 or 6 digits. For example, you will enter <b>000001 where you want the numbering to appear.

Note: If you do not use the <b> tag, the Bates number you entered in step #5 will repeat throughout the entire document.

7.    Select the font type and size. You can also change the margins if you need to.

8.    Select Ok and check your document.

Are the Bates numbers in the right place and on each page? Are the numbers in chronological order?  Great! You’re done.

If you are using Adobe Acrobat, you can find Bates numbering instructions here.

Litigation of serious personal injury cases can involve loads of documents. When you add multiple parties, the records you are responsible for increases drastically.  Bates stamping will make the document review and production process less of a headache for you and the attorney you support.

How about you: Do you have any bates stamping tips or tools to share? Please share them in the comments section below.

This article is part of the “How To” blog series in which I offer practical tips that paralegals can use to support attorneys before, during and after litigation. Subscribe to get updates so you won’t miss the next article in the series!

Can you believe we are halfway through the summer months? My kids will return to school in less than 3 weeks. Time is flying by!

I hope you have been enjoying yourself. I want to hear all about your summer adventures in the comments section below.

For the first time in years, I gave myself permission to take a break from the hustle and bustle of work, work, work – and spend more time refilling my cup with family and friends.

We have been gardening (check out my favorite hanging basket above!), sightseeing around Atlanta, making regular visits to the bookstore, and enjoying long walks in the park. The hubby and I have even managed to turn a few corners on our motorcycles – probably more corners than all of last year!

I’m almost embarrassed to tell you it has been many years since I’ve taken a break from work. Kind of insane, right? I realize that now. My body was running on fumes, literally … as I repeatedly burned the candle at both ends. I was exhausted, frustrated and stressed – which led to a ‘not-as-private-as-I’d-like’ meltdown.

Getting Back Into a Healthy Grind

While I have enjoyed my time away, it’s time to get back into a healthy grind! This has been an awesome week, so I want to stop for a moment to let you know what I have up my sleeves for you!

Here’s what you can expect in the coming days and weeks:

The “How-To” series is continuing.

A couple of months ago I kicked off a “how to” blog series covering tips legal professionals can use to support attorneys before, during and post litigation. My stats indicate those articles are the most popular on this blog. A couple of you have responded with “thank you” emails and suggestions for future content.

I am thrilled you are enjoying the articles! We will pick up where we left off – with a new article on Monday morning.  You expressed interest in PDF downloads of the articles, so I will make that happen.

Guest Bloggers are Welcome.

I am opening the series up to guest bloggers. Many of you are seasoned legal professionals, and I’m sure you have valuable information you can share with all of us. I’d love to include your practical tips in the series, so feel free to start submitting your ideas for guest posts via the contact page.

Videos are coming.

I receive several emails and calls from potential clients (and aspiring virtual paralegals and secretaries) with questions about my business, the services I provide, and how I work with my clients. So, I have decided to record a series of videos with my new Flip Ultra HD camera (affiliate link) answering your questions. You can expect the first video in the series next week!

Whew… enough updates for now! This post is getting long and I have to keep some surprises up my sleeves, right?

If you have any questions, suggestions, tips, advice or gripes, shoot me an email. I’d love to hear from you.

But before you leave… don’t forget to tell me all about your summer adventures in the comments section below!

This article is part of the “How To” blog series in which I offer practical tips that paralegals can use to support attorneys before, during and after litigation. Subscribe to get updates so you won’t miss the next article in the series!

Building a personal injury case is like writing a story. Dates and timing are important when determining what happened to an injured client.

Much like a medical summary, a thorough chronology (or timeline) will help the attorney you support understand the details and variables involved in the injury case.

As a litigation paralegal, you can create a medical chronology that the personal injury attorney will welcome by keeping these 5 simple steps in mind:

1. Focus on the Dates.

Unorganized medical records can be confusing. You want to create a chronology that includes a clear picture of the injured person’s medical condition and accompanying treatment before, during and after the accident. Every medical timeline should be date driven.

2. Detail Treatment Information.

It’s important to document the physicians that examined the client as well as the nature and progression of the medical treatment. This will help flesh out specifics about the extent of the client’s injuries and provide easy access to the information you need to locate expert witnesses and schedule depositions in the case.

3. Highlight the Injury.

In most PI cases, the client’s injuries do not occur in a vacuum, but due to another party’s negligence. The incident that caused the injury should be referenced in the medical chronology. Tying the injury to the medical treatment received is vital to the case.

4. Itemize Actual (and Special) Damages.

In addition to key medical information, I like to itemize the client’s bills, prescription expenses, lost wages and any other damages incurred as a result of the injury. You should also note how much the client (and the insurance company, if applicable) paid in the course of recovery.  These figures are essential when it comes to proving damages.

5. Future Medical Treatment?

Some people heal fully from their injuries – which is awesome! However, many others have ongoing heath issues that will plague them for the rest of their lives. It’s important that the medical chronology notes any future treatment the client will need.  This could include surgical interventions, weekly or monthly chiropractic adjustments, special in-home devices or medications.

Once a thorough medical chronology is created, it’s easier to get everyone involved in the case on the same page. It’s also a great tool that can be used strategically to develop a personal injury case that will get the client the best results possible.

How about you? Feel free to share any tips you have for creating medical chronologies and timelines in the comments section below.

One more thing before you go… I have to take a moment to acknowledge new subscribers to the series. WELCOME to the community! I’m SO grateful to have you here. I’d love to know more about what you want (or need) to see in the series. Please share any thoughts, questions and suggestions you have here.

In case you haven’t already, make sure YOU subscribe to the series to get updates every time a new article is published. You don’t want to miss any, do you?

This article is part of the “How To” blog series in which I offer practical tips that paralegals can use to support attorneys before, during and after litigation. Subscribe to get updates so you won’t miss the next article in the series!

Earlier in the series, we covered how to request medical records in 5 simple steps as well as organizing and indexing records once you receive them in office.

Now that you have the records organized, let’s discuss the next step you should take before you file the documents away.

Prepare a medical summary to outline the client’s injuries and treatment received from his or her physician. A well-crafted summary will save the injury attorney you’re supporting considerable time when it comes to document review.

There is no “right” way to prepare a medical summary, but here are 10 key components you must have:

1. Client (Patient) Information

Include the client’s full name and date of birth as well as the case style and your firm’s file  number. (I do not recommend including the SSN on this document.)

2. Medical Provider Information

It is common for a person to seek treatment from multiple medical providers. Make sure you identify the physician, hospital or facility whose records you are summarizing.

3. Date of Injury and Date of Visit

When reviewing medical records, it’s important to know the symptoms and treatment that took place before and after the injury. You also need to be on the lookout for any lapse in medical treatment. The DOI tells you when the injury occurred and in most instances, the first onset of pain and other symptoms.  The date of visit (whether it’s a single office visit or an extended period of care) should be included in the summary.

4. Chief Complaints

State the reason for the client’s visit to the doctor. What were the chief complaints described by the client?

5. Present Medical History

This is where you will summarize when and how the injuries occurred,  describe the symptoms, and list medications (if any) the client was taking at the time of the office visit. You also want to include any physicians that treated the client for the present injuries before the subject office visit (i.e. hospital emergency room).

6. Past Medical History

You want to make sure that the attorney and every team member is aware of any pre-existing injuries, illnesses or medical conditions. You should include information that is related (and unrelated) to the present medical history.

7. Physical Examination

It’s important to have a clear picture of the extent of the client’s injuries to truly understand the pain and suffering endured on the road to recovery. Summarize the results of any spinal or neurological exams, range of motion or orthopedic tests performed.

8. Diagnostic Studies and Findings

Were any xrays or CT scans done during the office visit? Any MRI’s scheduled? Include the date on which the xray was taken and the findings detailed on the report. If the physician requests additional studies, include that recommendation in the summary – and set a tickler to follow up until it’s done. (We’ll discuss setting up tickler systems in the near future.)

9. Diagnosis / Prognosis

The severity of an injury is often revealed in the diagnosis. In some records, it’s referred to as the “impression.”  Include the diagnosis in the medical summary as it will play a significant role in future treatment recommendations.  If the physician offers an opinion as to prognosis, you should add it to the summary as well.

10. Treatment Recommendations and Prescriptions

In this section, list the doctor’s recommendations. Was the client referred to a specialist or to physical therapy? Was a MRI or other radiology test ordered during the client’s visit?  If so, provide a brief summary of what was recommended. Be sure to include a list of any medications prescribed to the client.

There you have it… 10 must-have components of a medical summary!

Need help getting started? Download my Example Medical Summary form.

What’s Coming Up?

Next in this blog series, I will share practical tips you can use to create medical chronologies and timelines. You don’t want to miss it so make sure you subscribe to receive updates!