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the Plaintiff's Bodily Injury Deposition or Testimony Checklist and |
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the Spouse's BI Testimony Checklist. |
When it came to the trial, for the first five years doing defense work, I never could understand why the plaintiff never spent much time on the witness stand telling the real details that mean so much to the jury. Then it finally hit me,
Most plaintiff's attorneys never take the time to develop a complete checklist of the injury points to ask their client on the witness stand at trial.
And most defense attorneys never take the time to develop a complete checklist of the injury points to ask the plaintiff at the deposition.
That does not have to be you.
We develop the complete checklist for you!
The Plaintiff's Bodily Injury Deposition or Testimony
Checklist is for use with the injured person, is the more powerful form,
is designed for both plaintiffs and defendants, useful in both depositions and
trials, and is, quite frankly, may be the most expensive form we have on a dollar per
page basis. Yet, like all our
forms, if it saves you a half-hour of time - ever - it pays for itself.![]()
The Spouse's form
is primarily just for
plaintiff's counsel's trial use. But as a defense attorney for over 35
insurers and national self-insured companies, in five states, I always used this
form when taking the deposition of the spouse. I found that if the
plaintiff's attorney had not prepared the client sufficiently, I would uncover
some good testimony to minimize damages at the trial. By going through the
list of items, I would always come up with several items I could safely ask at
trial and get answers on a number of things that the spouse had told me at trial
had not been affected by the injuries. End a cross-exam at trial with 10
of those in quick succession and the plaintiff loses a lot ground with the jury.
You can have:
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the Plaintiff's Bodily Injury Deposition or Testimony Checklist and |
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the Spouse's BI Testimony Checklist. |
If you are a plaintiff's attorney, here are additional forms built for you.
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The IME Stipulation is a "must have" for a BI plaintiff lawyer's practice, a form that you can use to gain a quick written agreement to your benefit for the physical examination of the plaintiff. |
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And Client Handout for IME is what you need when defense counsel demands a medical exam of your client. Give your client great advice by means of our Client Handout for IME. |
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A plaintiff's busy law office can use Plaintiff's Request for Admissions Re Medical Expenses in the first 60 days after the defendant has answered, to prove up medical expenses and eliminate worry just before the trial about foundations for admission. |
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The Letter of Protection is a form letter you send the doctor who refuses to treat your client / her patient unless you agree to pay the doctor our of the settlement proceeds. |
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The BI Client Checklist is a compact one page form with three vital parts which you can hand to your client if you are a plaintiff's attorney. |
If you are a defense attorney, you will want to pay attention to:
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The Defense Attorney Treating Doctor's Medical Deposition Questions Checklist (10+ pages, a dozen major categories of inquiry) for defense counsel in taking the deposition of claimant's treating physician or surgeon. |