LETTERS OF PROTECTION IN GENERAL LIABIILTY CASES STRATEGIES FOR DEFENSE COUNSEL

Size: px
Start display at page:

Download "LETTERS OF PROTECTION IN GENERAL LIABIILTY CASES STRATEGIES FOR DEFENSE COUNSEL"

Transcription

1 LETTERS OF PROTECTION IN GENERAL LIABIILTY CASES STRATEGIES FOR DEFENSE COUNSEL Submitted by Joe Monello of Wicker, Smith, O Hara, McCoy & Ford, P.A. and Judy S. Davis, Corporate Risk Manager, Tallahassee Memorial Hospital A Letter of Protection (LOP) is a tool used to help an injured person pay for medical care they cannot afford or obtain without creating a substantial financial hardship. They have historically been used in auto cases, where personal injury protection (PIP) benefits are available. In recent years, the use of LOPs has become more prevalent in general liability and medical malpractice cases. These letters are generated by Plaintiff s attorneys to guarantee payment to health care providers. It is an agreement that allows the injured person to get medical care on credit with the healthcare provider agreeing to wait until the conclusion of the case to get payment from either a settlement or judgment. They are often signed by the Plaintiff and the healthcare provider, though they are sometimes signed by the Plaintiff s lawyers as well. Experience has shown that the use of LOPs in general liability and medical malpractice cases is not limited to circumstances where Plaintiffs do not have insurance that would otherwise pay for the care. Oftentimes, Plaintiffs who have private insurance, Medicare, or Medicaid still treat under an LOP, rather than submitting those bills. With reimbursement rates so low, and getting lower, many healthcare providers see LOPs as more financially beneficial to them. If it is a good liability case, with real injuries, the provider has a better opportunity for a higher percentage of reimbursement. Also, if the provider and the lawyer (or law firm) have an ongoing relationship, that lawyer will continually refer clients to that provider. The provider then has a financial incentive to help the Plaintiff s case, while the lawyer has incentive to refer more clients to that provider. So, what does that all mean for the defense of these cases? First and foremost, it affects the potential value of a case. What would a jury award this Plaintiff? Florida law generally provides that a Plaintiff is entitled to recover those reasonable medical expenses incurred from the negligence of another. When it comes to Medicare or Medicaid, the Plaintiff is limited to admitting at trial only the amount that Medicare or Medicaid paid, or is owed. For example, the

2 Plaintiff s total medical bills may be $100,000, but if Medicare only paid $10,000, the jury will be told the total medical bills are $10,000. With private insurance, the Plaintiff is able to admit the total amount of medical bills ($100,000 in the above example). After a verdict is rendered, and if the jury does award medical bills, the trial court will then do a post-trial set off. As such, even if a jury awards $100,000, the Plaintiff s recovery will be reduced to $10,000 in the above example. 1 With LOPs, not only can plaintiff s attorneys argue that the entire amount billed by the healthcare providers be admitted, but there is no post-trial set off. This allows for a larger potential recovery for the Plaintiff. STRATEGIES TO DEAL WITH LETTERS OF PROTECTION So, how do we defend cases involving letters of protection? Here are some strategies you may want to implement in your practice: 1. When obtaining medical records of a claimant or Plaintiff, make sure you get the complete record. Too often, healthcare providers provide only portions of their chart, and exclude billing or other financial records. By getting the entire record, you will be able to determine if a provider is providing care under a LOP, and get a copy of that document. 2. In a plaintiff s deposition, ask how she got referred to the treating physician or to the specialist. This will often meet with an objection as protected by attorney-client which will make the referral self-evident. Establishing who made the referral is oftentimes dispositive in order to seek further discovery regarding the letter of protection and any underlying referral relationship Depose the healthcare provider. Question that provider about the arrangement the provider has with the plaintiff s attorney. Ask whether part of that arrangement is to accept less than what has been billed despite having a LOP. If a physician admits to such 1 See Fla. Stat Compare Katzman v. Rediron Fabrication, Inc., 76 So. 3d 1060, 1064 (Fla. 4 th DCA 2011) (holding that a treating physician may have a stake in litigation because a lawyer referred his client to the doctor, and thus the doctor has injected himself into the litigation ) and Katzman v. Ranjana Corp., 90 So. 3d 873, 877 (Fla. 4 th DCA 2012) (holding that more in-depth discovery into a doctor s financial information to establish bias was improper because the patient was referred by another doctor, not by her attorney).

3 an arrangement but defers to his or her billing department for the specifics, then schedule the billing administrator for deposition. Ask the billing administrator how much the doctor would have been reimbursed if the charges had been submitted to a traditional health insurance company rather than under a LOP. You can then use this evidence to argue that charges were not reasonable. Also, ask the physician whether he socializes with and/or exchanges gifts with plaintiff s counsel. 4. Serve written discovery (requests to produce or interrogatories) on the relationship between the physician and the plaintiff s counsel. In Rediron, discovery into a treating physician and his practice s financial information was appropriate when there was a substantive issue regarding whether procedures were medically necessary, and whether the procedures were done solely due to the ongoing relationship between the lawyer and the physician. 3 This type of discovery is also permitted to determine whether the healthcare provider charges non-litigation patients a lower fee for the same medical services. Through this discovery you can also obtain information on the referral history from plaintiff s counsel; how the provider bills for those referrals; whether there is an individual letter of credit for each referral or a standing letter of credit to cover all referrals; and whether they meet to discuss billing/treatment issues. Defense counsel should also inquire as to the existence of a formal contract between the physician and plaintiff s counsel. 4 One objection defense counsel might encounter is that the discovery is barred under the strict guidelines of Florida Rule of Civil Procedure 1.280, regarding expert witness discovery, because the treating physician is a hybrid witness, i.e. one that testifies as to facts as well as medical opinions. However, Rule 1.280(b)(5) cannot be used as a shield to prevent discovery of relevant information from a material witness such as a treating physician by simply stating that the physician will also be an expert witness in 3 See Rediron, 76 So. 3d at See Steinger, Iscoe & Greene, P.A. v. Geico General Ins. Co., 103 So. 3d 200, 205 (Fla. 4 th DCA 2012) ( [W]here there is a preliminary showing that the plaintiff was referred to the doctor by the lawyer (whether directly or through a third party) or vice versa, the defendant is entitled to discover information regarding the extent of the relationship between the law firm and the doctor. ).

4 litigation. 5 Courts have reasoned that this type of discovery is pertinent especially because [a] physician may derive substantial income from treating patients involved in litigation beyond the provision of services as a retained expert. 6 While this information is discoverable, however, it must not be overly-intrusive. 7 Financial information should normally be sought first from the party, the treating doctor, or other witnesses, rather than the party s legal counsel. 8 In the event that none of these sources has sufficient information, or if the witnesses give nebulous testimony, a law firm is an appropriate source of discovery for information regarding a firm s financial relationship with a doctor Finally, consider using a medical expert or billing/coding expert to render an opinion on what the true cost of the medical services would have been if actually submitted to Medicare/Medicaid or to a private insurance company. Some providers who bill under an LOP may take liberties in the way they code certain treatments or procedures, placing them in a higher acuity level, and thus making them more expensive. 10 These experts would allow the jury to hear an alternative damage number to reduce the medical award. Each case is different, and the strategy implemented will be case specific. However, by implementing one or more of these strategies, you will hopefully be able to decrease the potential value of the case by proving the bias of the provider and the unreasonableness of the bills. Good Luck! 5 See id. at See Brown v. Mittlelman, 390 Fla. L. Weekly D1806, at *1 (Fla. 4 th DCA 2014). 7 See id. at *2; accord Elkins v. Syken, 672 So. 2d 517, 522 (Fla. 1996) (holding that discovery should not be used as a tactical tool to harass, and that courts must balance a party s need for information concerning potential witness bias and the witness s right to be free from burdensome or intrusive production requests). 8 See Steinger, 103 So. 3d at See Lytal, Reiter, Smith, Ivey & Fronrath, L.L.P. v. Malay, 133 So. 3d 1178 (Fla. 4 th DCA 2014). 10 See Rediron, 76 So. 3d at 1064.

5 Joe Monello, Attorney At Law Wicker Smith O Hara McCoy & Ford P.A. 390North Orange Avenue, Suite 1000 Orlando, FL Tel: Fax: Judy S. Davis, MS, LHRM, CHRM Corporate Risk Manager Tallahassee Memorial Hospital 1300 Miccosukee Road Tallahassee, FL Tel: (850)

PHANTOM DAMAGES IN PERSONAL INJURY CASES:

PHANTOM DAMAGES IN PERSONAL INJURY CASES: PHANTOM DAMAGES IN PERSONAL INJURY CASES: The Legal Landscape Andrew S. Connell, Jr. Litchfield Cavo LLP 600 Corporate Drive, Suite 600 Fort Lauderdale, FL 33334 954-689-3000 connell@litchfieldcavo.com

More information

DISCOVERY FROM EXPERT WITNESSES 1

DISCOVERY FROM EXPERT WITNESSES 1 DISCOVERY FROM EXPERT WITNESSES 1 Discovery from retained and even involved experts can be difficult and the process frustrating. Some basic understanding of what is discoverable and what is not from experts

More information

IN THE SUPREME COURT OF FLORIDA CASE NO. SC05-1150 COMMENTS OF DAN CYTRYN, ESQUIRE OF LAW OFFICES CYTRYN & SANTANA, P.A.

IN THE SUPREME COURT OF FLORIDA CASE NO. SC05-1150 COMMENTS OF DAN CYTRYN, ESQUIRE OF LAW OFFICES CYTRYN & SANTANA, P.A. IN THE SUPREME COURT OF FLORIDA CASE NO. SC05-1150 IN RE: PETITION TO AMEND RULE 4-1.5(F)(4)(B) OF THE RULES OF PROFESSIONAL CONDUCT / COMMENTS OF DAN CYTRYN, ESQUIRE OF LAW OFFICES CYTRYN & SANTANA, P.A.

More information

CIVIL DIVISION PLAINTIFF S PROPOSED JURY INSTRUCTIONS. The Plaintiff, JENNIFER WINDISCH, by and through undersigned counsel, and

CIVIL DIVISION PLAINTIFF S PROPOSED JURY INSTRUCTIONS. The Plaintiff, JENNIFER WINDISCH, by and through undersigned counsel, and IN THE CIRCUIT COURT OF THE 16TH JUDICIAL CIRCUIT IN AND FOR MONROE COUNTY, FLORIDA JENNIFER WINDISCH, Plaintiff, v. CIVIL DIVISION CASE NO: 2007-CA-1174-K JOHN SUNDIN, M.D., RHODA SMITH, M.D., LAURRAURI

More information

FARAH & FARAH RULES OF LAW

FARAH & FARAH RULES OF LAW RULES OF LAW Injury Case Roadmap: The Legal Process for Personal Injury Cases BY EDDIE E. FARAH & CHARLIE E. FARAH, ATTORNEYS AT LAW ...insurance companies more and more are being run by bean counters,...

More information

Learning How To Be Your Own Best Advocate

Learning How To Be Your Own Best Advocate Learning How To Be Your Own Best Advocate The Impor tance of Medical Evidence in Personal Injur y Claims Managing Your Medical Treatment After An Accident By Chris Davis, Attorney at Law Davis Law Group,

More information

Discovery Depositions 1 Part I: Practical Considerations in Planning and Preparing to Take a Discovery Deposition

Discovery Depositions 1 Part I: Practical Considerations in Planning and Preparing to Take a Discovery Deposition Discovery Depositions 1 Part I: Practical Considerations in Planning and Preparing to Take a Discovery Deposition Purpose of Depositions: Perpetuate testimony Discover knowledge of facts and observations

More information

WICKER SMITH O HARA MCCOY & FORD P.A. Torts Premises Liability Slip and Fall. Civil Procedure. Torts Automobile Accident Discovery

WICKER SMITH O HARA MCCOY & FORD P.A. Torts Premises Liability Slip and Fall. Civil Procedure. Torts Automobile Accident Discovery WICKER SMITH O HARA MCCOY & FORD P.A. SEPTEMBER / OCTOBER 2014 Torts Premises Liability Slip and Fall Civil Procedure Torts Automobile Accident Discovery Wrongful Death Workers Compensation Immunity Attorney

More information

THE DEFENSE LAWYER S TOOL KIT FOR WORKING WITH MEDICAL EXPERTS

THE DEFENSE LAWYER S TOOL KIT FOR WORKING WITH MEDICAL EXPERTS THE DEFENSE LAWYER S TOOL KIT FOR WORKING WITH MEDICAL EXPERTS ABA Tort Trial & Insurance Practice Section Medicine and Law Committee Annual Meeting August 1, 2009 Jessie L. Harris Williams Kastner 601

More information

I. Elements of a Commercial Premises Liability Claim:

I. Elements of a Commercial Premises Liability Claim: I. Elements of a Commercial Premises Liability Claim: Generally, persons who own or occupy premises may be liable for the injury to a person, i.e. visitor, on the premises that are under their occupation

More information

SUPREME COURT OF FLORIDA Case No. SC05-1150

SUPREME COURT OF FLORIDA Case No. SC05-1150 SUPREME COURT OF FLORIDA Case No. SC05-1150 In Re: Petition to Amend Rule Rule 4-1.5(f)(4)(B) of the Rules of Professional Conduct / as follows: RESPONSE OF HARRY A. SHEVIN, ESQUIRE IN OPPOSITION TO PETITION

More information

This is the appeal of an Amended Final Judgment Awarding Costs and Attorney's

This is the appeal of an Amended Final Judgment Awarding Costs and Attorney's IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT, IN AND FOR SEMINOLE COUNTY, FLORIDA STATE FARM MUTUAL AUTOMOBILE APPELLATE DIVISION INSURANCE COMPANY, CASE NO.: 00-14 L.T. CASE NO.: 97-769-CC

More information

Putting Excessive Attorneys Fees Claims Out to Pasture HILL WARD HENDERSON ATTORNEYS AT LAW

Putting Excessive Attorneys Fees Claims Out to Pasture HILL WARD HENDERSON ATTORNEYS AT LAW PUTTING EXCESSIVE ATTORNEYS FEES CLAIMS OUT TO PASTURE RELYING ON A STATUTORY CAP TO PREVENT MOTOR VEHICLE DEALER BOND SURETIES FROM BEING MILKED LIKE CASH COWS PRESENTERS: Gregory P. Brown, Esq. Hill

More information

Personal Injury Litigation

Personal Injury Litigation Personal Injury Litigation The Anatomy of a New York Personal Injury Lawsuit An ebook by Stuart DiMartini, Esq. 1325 Sixth Avenue, 27 th Floor New York, NY 10019 212-5181532 dimartinilaw.com Introduction

More information

ATTORNEY HELP CENTER: MEDICAL MALPRACTICE

ATTORNEY HELP CENTER: MEDICAL MALPRACTICE ATTORNEY HELP CENTER: MEDICAL MALPRACTICE The healthcare industry has exploded over the last thirty years. Combined with an increasing elderly population, thanks to the Baby Boomer generation, the general

More information

EMERGING ISSUES IN LEGAL MALPRACTICE DEFENSE

EMERGING ISSUES IN LEGAL MALPRACTICE DEFENSE FDCC Winter Meeting Hyatt Grand Champions Resort Indian Wells, California February 26 March 5, 2011 EMERGING ISSUES IN LEGAL MALPRACTICE DEFENSE Presented by Professional Liability Section Richards H.

More information

The Effect of Product Safety Regulatory Compliance

The Effect of Product Safety Regulatory Compliance PRODUCT LIABILITY Product Liability Litigation The Effect of Product Safety Regulatory Compliance By Kenneth Ross Product liability litigation and product safety regulatory activities in the U.S. and elsewhere

More information

No. 64,976. [November 1, 1984] The Supreme Court Committee on Standard Jury Instructions

No. 64,976. [November 1, 1984] The Supreme Court Committee on Standard Jury Instructions ,. No. 64,976 THE FLORIDA BAR RE: STANDARD JURY INSTRUCTIONS - CIVIL (PROFESSIONAL l1alpractice) [November 1, 1984] McDONALD, J. The Supreme Court Committee on Standard Jury Instructions (Civil) has submitted

More information

PAID OR INCURRED UPDATE The Aftermath of Haygood v. de Escabedo

PAID OR INCURRED UPDATE The Aftermath of Haygood v. de Escabedo PAID OR INCURRED UPDATE The Aftermath of Haygood v. de Escabedo JOE ESCOBEDO Escobedo, Tippit & Cardenas, L.L.P. 3900 N. 10 th Street, Suite 950 McAllen, Texas 78501 (956) 618-3357 Paid or Incurred Update

More information

CASE NO. 1D15-1966. The instant appeal originated with a medical malpractice complaint filed by

CASE NO. 1D15-1966. The instant appeal originated with a medical malpractice complaint filed by IN THE DISTRICT COURT OF APPEAL FIRST DISTRICT, STATE OF FLORIDA JAN COLVIN AND WADE COLVIN, v. Appellants, NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING AND DISPOSITION THEREOF IF FILED CASE

More information

Birth Trauma: Litigating Medical Malpractice Cases in Numerous States

Birth Trauma: Litigating Medical Malpractice Cases in Numerous States Birth Trauma: Litigating Medical Malpractice Cases in Numerous States is currently litigating birth trauma cases throughout the country. The firm s attorneys are licensed to practice law in Texas, Louisiana

More information

Supreme Court of Florida

Supreme Court of Florida Supreme Court of Florida No. SC02-2659 CYNTHIA CLEFF NORMAN, Petitioner, vs. TERRI LAMARRIA FARROW, Respondent. [June 24, 2004] WELLS, J. We have for review Norman v. Farrow, 832 So. 2d 158 (Fla. 1st DCA

More information

WASHINGTON COLLEGE OF LAW, AMERICAN UNIVERSITY MEDICAL LIABILITY & PUBLIC HEALTH PROFESSOR STEVEN M. PAVSNER SYLLABUS

WASHINGTON COLLEGE OF LAW, AMERICAN UNIVERSITY MEDICAL LIABILITY & PUBLIC HEALTH PROFESSOR STEVEN M. PAVSNER SYLLABUS I. Synopsis WASHINGTON COLLEGE OF LAW, AMERICAN UNIVERSITY MEDICAL LIABILITY & PUBLIC HEALTH PROFESSOR STEVEN M. PAVSNER SYLLABUS The objective of the seminar, Medical Liability and Public Health, is to

More information

What Trustees Should Know About Florida s New Attorneys Fee Statute. By David P. Hathaway and David J. Akins. Introduction

What Trustees Should Know About Florida s New Attorneys Fee Statute. By David P. Hathaway and David J. Akins. Introduction What Trustees Should Know About Florida s New Attorneys Fee Statute By David P. Hathaway and David J. Akins Introduction More and more lawsuits are filed in Florida alleging that the trustee of a trust

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA RONALD DUTTON, : : Consolidated Under Plaintiff, : MDL DOCKET NO. 875 : v. : CIVIL ACTION NO. : 09-62916 TODD SHIPYARDS CORP.,

More information

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA PROGRESSIVE AMERICAN INSURANCE COMPANY, CASE NO.: 2014-CV-000079-A-O Lower Case No.: 2012-SC-002127-O Appellant, v.

More information

[July 16, 19871 REVISED OPINION. We have for review two cases of the district courts of

[July 16, 19871 REVISED OPINION. We have for review two cases of the district courts of FLORIDA PATIENT'S COMPENSATION FUND, Petitioner, VS. GEORGE BOUCHOC, et a1., Respondents. No. 69,230 WINTER HAVEN HOSPITAL, INC., Petitioner, VS. No. 69,493 FLORIDA PATIENT'S COMPENSATION FUND, Respondent.

More information

REFERENCE ACTION ANALYST STAFF DIRECTOR or. 1) Civil Justice Subcommittee 8 Y, 5 N, As CS Malcolm Bond

REFERENCE ACTION ANALYST STAFF DIRECTOR or. 1) Civil Justice Subcommittee 8 Y, 5 N, As CS Malcolm Bond HOUSE OF REPRESENTATIVES STAFF ANALYSIS BILL #: CS/HB 1199 Damages in Personal Injury Actions SPONSOR(S): Civil Justice Subcommittee; Metz and others TIED BILLS: None IDEN./SIM. BILLS: SB 1240 REFERENCE

More information

Addressing Abusive Lawyer Conduct in Relation to Litigation Proceedings

Addressing Abusive Lawyer Conduct in Relation to Litigation Proceedings Author: Attorney Dan A. Riegleman N63 W23965 Main Street Sussex, Wisconsin 53089 Prepared: 06/01/10 WHITE PAPER: DR2504 Addressing Abusive Lawyer Conduct in Relation to Litigation Proceedings There are

More information

PUBLICATION PROVIDED BY: RISSMAN, BARRETT, HURT DONAHUE & McLAIN, P.A.

PUBLICATION PROVIDED BY: RISSMAN, BARRETT, HURT DONAHUE & McLAIN, P.A. PUBLICATION PROVIDED BY: RISSMAN, BARRETT, HURT DONAHUE & McLAIN, P.A. 201 EAST PINE STREET 15 TH FLOOR P.O. BOX 4940 ORLANDO, FLORIDA 32802-4940 TELEPHONE (407) 839-0120 TELECOPIER (407) 841-9726 ORLANDO@RISSMAN.COM

More information

NOT FINAL UNTIL TIME EXPIRES TO FILE REHEARING MOTION AND, IF FILED, DETERMINED IN THE DISTRICT COURT OF APPEAL

NOT FINAL UNTIL TIME EXPIRES TO FILE REHEARING MOTION AND, IF FILED, DETERMINED IN THE DISTRICT COURT OF APPEAL NOT FINAL UNTIL TIME EXPIRES TO FILE REHEARING MOTION AND, IF FILED, DETERMINED IN THE DISTRICT COURT OF APPEAL OF FLORIDA SECOND DISTRICT ALFREDO MEJIA, ) ) Appellant, ) ) v. ) Case No. 2D13-2248 ) CITIZENS

More information

Lowcountry Injury Law

Lowcountry Injury Law Lowcountry Injury Law 1917 Lovejoy Street Post Office Drawer 850 Beaufort, South Carolina 29901 Personal Injury Phone (843) 524-9445 Auto Accidents Fax (843) 532-9254 Workers Comp DanDenton@Lawyer.com

More information

Memorandum. Trial Counsel in Medical Malpractice Cases. John E. Wetsel, Jr., Judge. From: Date: December 11, 2012. Sample Instructions.

Memorandum. Trial Counsel in Medical Malpractice Cases. John E. Wetsel, Jr., Judge. From: Date: December 11, 2012. Sample Instructions. Memorandum To: From: Trial Counsel in Medical Malpractice Cases John E. Wetsel, Jr., Judge Date: December 11, 2012 Subject: Sample Instructions ============================== Here is a complete set of

More information

THE THREAT OF BAD FAITH LITIGATION ETHICAL HANDLING OF CLAIMS AND GOOD FAITH SETTLEMENT PRACTICES. By Craig R. White

THE THREAT OF BAD FAITH LITIGATION ETHICAL HANDLING OF CLAIMS AND GOOD FAITH SETTLEMENT PRACTICES. By Craig R. White THE THREAT OF BAD FAITH LITIGATION ETHICAL HANDLING OF CLAIMS AND GOOD FAITH SETTLEMENT PRACTICES By Craig R. White SKEDSVOLD & WHITE, LLC. 1050 Crown Pointe Parkway Suite 710 Atlanta, Georgia 30338 (770)

More information

2012 CASE LAW SUMMARY. Automobile Liability

2012 CASE LAW SUMMARY. Automobile Liability 2012 CASE LAW SUMMARY Automobile Liability Accident Report Privilege Sottilaro v. Figueroa, 86 So. 3d 505 (Fla. 2d DCA 2012) Sottilaro's car struck and killed a 14-year-old boy as he tried to cross a fourlane

More information

UTAH. Past medical expenses may be recovered. Plaintiffs must show that they have been injured and,

UTAH. Past medical expenses may be recovered. Plaintiffs must show that they have been injured and, UTAH Rick L. Rose Kristine M. Larsen RAY QUINNEY & NEBEKER P.C. 36 South State Street, Suite 1400 P.O. Box 43585 Salt Lake City, Utah 84111 Telephone: (801) 532-1500 Facsimile: (801) 532-7543 rrose@rqn.com

More information

My Attorney. What A Personal Injury Lawyer Can Do For You. By Christopher M. Davis, Attorney at Law

My Attorney. What A Personal Injury Lawyer Can Do For You. By Christopher M. Davis, Attorney at Law My Attorney What A Personal Injury Lawyer Can Do For You By Christopher M. Davis, Attorney at Law Davis Law Group, P.S. 2101 Fourth Avenue Suite 630 Seattle, WA 98121 206-727-4000 Davis Law Group, P.S.

More information

FURR & HENSHAW. http://www.scmedicalmalpractice.com

FURR & HENSHAW. http://www.scmedicalmalpractice.com FURR & HENSHAW http://www.scmedicalmalpractice.com 1900 Oak Street Post Office Box 2909 Myrtle Beach, South Carolina 29578 (843) 626-7621 (800) 849-2525 fho@sc.rr.com and 1534 Blanding Street Columbia,

More information

Injury Accident Guide

Injury Accident Guide Injury Accident Guide 7035 Jefferson Highway Baton Rouge, Louisiana 70806 Ph: 225-928-8800 Toll Free: 800-734-6545 Fax: 225-928-8802 Written by Peyton Murphy of Murphy Law Firm, LLC TABLE OF CONTENTS 1)

More information

MICHAEL D. WAKS LONG BEACH PERSONAL INJURY ATTORNEY

MICHAEL D. WAKS LONG BEACH PERSONAL INJURY ATTORNEY WHAT IS LEGAL MALPRACTICE IN CALIFORNIA? A client who sustains harm as a direct result of legal malpractice can file a civil lawsuit against the attorney who was responsible for causing that harm. MICHAEL

More information

AUTHORITY TO REPRESENT AND CONTINGENCY FEE AGREEMENT

AUTHORITY TO REPRESENT AND CONTINGENCY FEE AGREEMENT AUTHORITY TO REPRESENT AND CONTINGENCY FEE AGREEMENT I, the undersigned client, do hereby retain and employ the Law Offices Of Zarakhovich&Associates, Inc., and, specifically, attorney Mariya Zarakhovich,

More information

Compulsory Arbitration

Compulsory Arbitration Local Rule 1301 Scope. Compulsory Arbitration Local Rule 1301 Scope. (1) The following civil actions shall first be submitted to and heard by a Board of Arbitrators: (a) (b) (c) (d) Civil actions, proceedings

More information

CRIMINAL DEFENSE AGREEMENTS

CRIMINAL DEFENSE AGREEMENTS 5/6/13 CRIMINAL DEFENSE & CIVIL LITIGATION AGREEMENTS LLOYD M. CUETO LAW OFFICE OF LLOYD M. CUETO P.C. 7110 WEST MAIN STREET BELLEVILLE, ILLINOIS 62223 (618) 277-1554 CRIMINAL DEFENSE AGREEMENTS HOW TO

More information

PRIVATE ATTORNEY SERVICES DIVISION OF RISK MANAGEMENT BUREAU OF CLAIMS ADMINISTRATION INTRODUCTION TO BILLING GUIDELINES

PRIVATE ATTORNEY SERVICES DIVISION OF RISK MANAGEMENT BUREAU OF CLAIMS ADMINISTRATION INTRODUCTION TO BILLING GUIDELINES PRIVATE ATTORNEY SERVICES DIVISION OF RISK MANAGEMENT BUREAU OF CLAIMS ADMINISTRATION INTRODUCTION TO BILLING GUIDELINES The Division of Risk Management, Bureau of Claims Administration, (Division) is

More information

Common Myths About Personal Injury and Wrongful Death Cases 1. By B. Keith Williams

Common Myths About Personal Injury and Wrongful Death Cases 1. By B. Keith Williams Common Myths About Personal Injury and Wrongful Death Cases 1 By B. Keith Williams There are several myths about accident cases and the attorneys that handle them. It is important to keep these myths in

More information

IN THE DISTRICT COURT OF WYANDOTTE COUNTY, KANSAS PLAINTIFF S PROPOSED JURY INSTRUCTIONS

IN THE DISTRICT COURT OF WYANDOTTE COUNTY, KANSAS PLAINTIFF S PROPOSED JURY INSTRUCTIONS IN THE DISTRICT COURT OF WYANDOTTE COUNTY, KANSAS KC Plaintiff ) ) Plaintiff, ) ) v. ) Case No.: 06 CV 1383 ) Defendant Doctor ) ) Defendant. ) PLAINTIFF S PROPOSED JURY INSTRUCTIONS Plaintiff submits

More information

Your Accident Attorney

Your Accident Attorney Your Accident Attorney What a Personal Injury Attorney Can Do For You By Ross A. Jurewitz Injury Accident Attorney, Jurewitz Law Group Jurewitz Law Group 600 B Street Suite San Diego, CA 92101 Tel: 619-233-5020

More information

RULE 4-1.5 FEES AND COSTS FOR LEGAL SERVICES

RULE 4-1.5 FEES AND COSTS FOR LEGAL SERVICES RULE 4-1.5 FEES AND COSTS FOR LEGAL SERVICES (a) Illegal, Prohibited, or Clearly Excessive Fees and Costs. [no change] (b) Factors to Be Considered in Determining Reasonable Fees and Costs. [no change]

More information

Advocate Magazine March 2011. Why medical malpractice still matters.

Advocate Magazine March 2011. Why medical malpractice still matters. Advocate Magazine March 2011 Why medical malpractice still matters. Despite MICRA limitations, medical-negligence claims still have a crucial role in society BY BRUCE G. FAGEL We all know the statistics

More information

Office of Bar Counsel 525 West Jefferson P. O. Box 895 Boise, Idaho 83701 (208) 334-4500 Fax: (208) 334-2764 www.isb.idaho.gov

Office of Bar Counsel 525 West Jefferson P. O. Box 895 Boise, Idaho 83701 (208) 334-4500 Fax: (208) 334-2764 www.isb.idaho.gov Office of Bar Counsel 525 West Jefferson P. O. Box 895 Boise, Idaho 83701 (208) 334-4500 Fax: (208) 334-2764 www.isb.idaho.gov CLIENT ASSISTANCE FUND CLAIM FORM GENERAL INFORMATION AND INSTRUCTIONS Under

More information

MULTIPLE REPRESENTATION AND DRAFTING CONTINGENCY FEE AGREEMENTS

MULTIPLE REPRESENTATION AND DRAFTING CONTINGENCY FEE AGREEMENTS MULTIPLE REPRESENTATION AND DRAFTING CONTINGENCY FEE AGREEMENTS ADVANCED PERSONAL INJURY LAW COURSE CLE TEXAS STATE BAR 2013 S AM J OHNSON S COTT, DOUGLASS & MC C ONNICO, L.L.P. A TTORNEYS A T L AW WWW.

More information

Managing Jones Act Personal Injury Litigation The Vessel Owner s Perspective. Lawrence R. DeMarcay, III

Managing Jones Act Personal Injury Litigation The Vessel Owner s Perspective. Lawrence R. DeMarcay, III Managing Jones Act Personal Injury Litigation The Vessel Owner s Perspective by Lawrence R. DeMarcay, III Presented to the Offshore Marine Services Association / Loyola College of Law Industry Seminar

More information

CASE INFORMATION SHEET FLORIDA LEGAL PERIODICALS, INC. P.O. Box 3370, Tallahassee, FL 32315-3730 (904) 224-6649/(800) 446-2998 * FAX (850) 222-6266

CASE INFORMATION SHEET FLORIDA LEGAL PERIODICALS, INC. P.O. Box 3370, Tallahassee, FL 32315-3730 (904) 224-6649/(800) 446-2998 * FAX (850) 222-6266 CASE INFORMATION SHEET FLORIDA LEGAL PERIODICALS, INC. P.O. Box 3370, Tallahassee, FL 32315-3730 (904) 224-6649/(800) 446-2998 * FAX (850) 222-6266 COUNTY AND COURT: Pasco County Florida NAME OF CASE:

More information

AVOIDING THE PITFALLS WORKERS' COMPENSATION LAW YOU NEED TO KNOW FOR YOUR PERSONAL INJURY PRACTICE

AVOIDING THE PITFALLS WORKERS' COMPENSATION LAW YOU NEED TO KNOW FOR YOUR PERSONAL INJURY PRACTICE AVOIDING THE PITFALLS WORKERS' COMPENSATION LAW YOU NEED TO KNOW FOR YOUR PERSONAL INJURY PRACTICE Presented for the Bar Association Of the City of Richmond February 21, 2001 ".., By: Andrew J. Reinhardt,

More information

Joseph P. Menello Wicker, Smith, O Hara, McCoy & Ford, P.A. jmenello@wickersmith.com

Joseph P. Menello Wicker, Smith, O Hara, McCoy & Ford, P.A. jmenello@wickersmith.com Joseph P. Menello Wicker, Smith, O Hara, McCoy & Ford, P.A. jmenello@wickersmith.com Plaintiff brought an action against the hospital, anesthesiologist, and provider of anesthesiologists and nurse anesthetics

More information

COMMENTS OF MARK P. CRESSMAN, ESQUIRE FLORIDA BAR NO: 0051519 AND OBJECTIONS TO PROPOSED AMENDMENT

COMMENTS OF MARK P. CRESSMAN, ESQUIRE FLORIDA BAR NO: 0051519 AND OBJECTIONS TO PROPOSED AMENDMENT IN RE: PETITION TO AMEND RULE 4-1.5(f)(4)(B) OF THE RULES OF PROFESSIONAL CONDUCT / IN THE SUPREME COURT OF THE STATE OF FLORIDA CASE NO.: SC05-1150 COMMENTS OF MARK P. CRESSMAN, ESQUIRE FLORIDA BAR NO:

More information

ON PROPOSED AMENDMENTS TO MEDIATION RULES

ON PROPOSED AMENDMENTS TO MEDIATION RULES THE SUPREME COURT STATE OF FLORIDA IN RE: AMENDMENT TO FLORIDA RULES OF CIVIL PROCEDURE 1.700-1.780 (MEDIATION) CASE NO. 75,151 FLORIDA MEDICAL MALPRACTICE CLAIMS COUNCIL, INC.'S COMMENTS ON PROPOSED AMENDMENTS

More information

The Defense Lawyer s Tool Kit For Working With Medical Experts

The Defense Lawyer s Tool Kit For Working With Medical Experts The Defense Lawyer s Tool Kit For Working With Medical Experts Jessie L. Harris You may have to play catch-up, but you can play it to win. Jessie L. Harris is a trial lawyer and Member in the Seattle office

More information

Case 6:12-cv-00914-RBD-TBS Document 136 Filed 07/16/14 Page 1 of 7 PageID 4525

Case 6:12-cv-00914-RBD-TBS Document 136 Filed 07/16/14 Page 1 of 7 PageID 4525 Case 6:12-cv-00914-RBD-TBS Document 136 Filed 07/16/14 Page 1 of 7 PageID 4525 TROVILLION CONSTRUCTION & DEVELOPMENT, INC.; and CASA JARDIN CONDOMINIUM ASSOCIATION, INC., UNITED STATES DISTRICT COURT MIDDLE

More information

Table of Contents. 1. What should I do when the other driver s insurance company contacts me?... 1

Table of Contents. 1. What should I do when the other driver s insurance company contacts me?... 1 Table of Contents 1. What should I do when the other driver s insurance company contacts me?... 1 2. Who should be paying my medical bills from a car accident injury?... 2 3. What should I do after the

More information

SUPREME COURT OF FLORIDA Case No. SC05-1150

SUPREME COURT OF FLORIDA Case No. SC05-1150 SUPREME COURT OF FLORIDA Case No. SC05-1150 In Re: Petition to Amend Rule Rule 4-1.5(f)(4)(B) of the Rules of Professional Conduct / RESPONSE OF CHRISTIAN D. SEARCY ON BEHALF OF THE 21 MEMBERS IN GOOD

More information

Listen to Your Doctor and Theirs: The Treating Physician as An Expert Witnesses

Listen to Your Doctor and Theirs: The Treating Physician as An Expert Witnesses The DelliCarpini Law Firm Melville Law Center 877.917.9560 225 Old Country Road fax 631.923.1079 Melville, NY 11747 www.dellicarpinilaw.com John M. DelliCarpini Christopher J. DelliCarpini (admitted in

More information

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA BARBRA R. JOYNER, Appellant, CASE NO.: 2012-CV-000003-A-O Lower Case No.: 2010-CC-010676-O v. ONE THOUSAND OAKS, INC.,

More information

Question 5. After the trial, Attorney sent a $500 gift certificate to Doctor, with a note thanking her for recommending that Peter call him.

Question 5. After the trial, Attorney sent a $500 gift certificate to Doctor, with a note thanking her for recommending that Peter call him. Question 5 Attorney mailed a professional announcement to several local physicians, listing his name and address and his area of law practice as personal injury. Doctor received Attorney s announcement

More information

SPECIAL CIVIL A GUIDE TO THE COURT

SPECIAL CIVIL A GUIDE TO THE COURT NEW JERSEY JUDICIARY SPECIAL CIVIL A GUIDE TO THE COURT Superior Court of New Jersey Law Division Special Civil Part Special Civil A Guide to the Court page 1 Special Civil is a court of limited jurisdiction

More information

Discovery in Bad Faith Insurance Claims: State of the Law, Successful Strategies. Teleconference Program Wednesday, March 29, 2006

Discovery in Bad Faith Insurance Claims: State of the Law, Successful Strategies. Teleconference Program Wednesday, March 29, 2006 Discovery in Bad Faith Insurance Claims: State of the Law, Successful Strategies Teleconference Program Wednesday, March 29, 2006 Topic III A. Who is suing? Does it matter? 1. Whether suit is brought by

More information

S.B. 88 126th General Assembly (As Introduced)

S.B. 88 126th General Assembly (As Introduced) Elizabeth Dominic Bill Analysis Legislative Service Commission S.B. 88 126th General Assembly (As Introduced) Sens. Coughlin, Goodman BILL SUMMARY Requires the Superintendent of Insurance to establish

More information

Your Legal Rights and Options in this Class Action Lawsuit:

Your Legal Rights and Options in this Class Action Lawsuit: Circuit Court For The 13 th Judicial Circuit In And For Hillsborough County, Florida If you provided health care treatment or services to people insured by United Services Automobile Association, USAA

More information

WHAT HAPPENS IN A PERSONAL INJURY CASE

WHAT HAPPENS IN A PERSONAL INJURY CASE WHAT HAPPENS IN A PERSONAL INJURY CASE From Negotiating With Insurance Companies To Trial By Michael A. Schafer, Attorney at Law 440 South Seventh Street, Ste. 200 Louisville, Kentucky 40203 (502) 584-9511

More information

A. Sample of a Retainer Agreement in a personal injury case which does not involve medical, dental or podiatric malpractice:

A. Sample of a Retainer Agreement in a personal injury case which does not involve medical, dental or podiatric malpractice: OUR RETAINER AGREEMENTS Here are samples of our Retainer Agreements which determine the recovery of our legal fees once we have been successful in recovering compensation on behalf of a victim in a personal

More information

1, 2011, and will apply to payment obligations assumed on or after October 1, 2010. See

1, 2011, and will apply to payment obligations assumed on or after October 1, 2010. See Medicare Reporting and Reimbursement Compliance Issues in Mass Products Liability Cases in which Exposure on or after December 5, 1980, is Generally Alleged, Established, and/or Released. By: Lynn O. Frye,

More information

IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY FIRST JUDICIAL DISTRICT OF PENNSYLVANIA CIVIL TRIAL DIVISION

IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY FIRST JUDICIAL DISTRICT OF PENNSYLVANIA CIVIL TRIAL DIVISION IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY FIRST JUDICIAL DISTRICT OF PENNSYLVANIA CIVIL TRIAL DIVISION JOHN FRAZIER HUNT, : DECEMBER TERM, 2004 Plaintiff, : No. 2742 v. : (Commerce Program) NATIONAL

More information

LegalFormsForTexas.Com

LegalFormsForTexas.Com Information or instructions: acknowledgment Personal injury settlement statement and client 1. The following form may be used as part of a personal injury settlement. 2. The form is a disclosure statement

More information

Case 1:07-cv-00389-MJW-BNB Document 51 Filed 08/21/2008 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 1:07-cv-00389-MJW-BNB Document 51 Filed 08/21/2008 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case 1:07-cv-00389-MJW-BNB Document 51 Filed 08/21/2008 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 07-cv-00389-MJW-BNB ERNA GANSER, Plaintiff, v. ROBERT

More information

ASSEMBLY BILL No. 597

ASSEMBLY BILL No. 597 california legislature 2015 16 regular session ASSEMBLY BILL No. 597 Introduced by Assembly Member Cooley February 24, 2015 An act to amend Sections 36 and 877 of, and to add Chapter 6 (commencing with

More information

The Impact of Social Media on Damages in Employment Litigation. By: Angie C. Davis and Mary Wu

The Impact of Social Media on Damages in Employment Litigation. By: Angie C. Davis and Mary Wu The Impact of Social Media on Damages in Employment Litigation By: Angie C. Davis and Mary Wu Everyone Facebook stalks - even (or shall I say especially) plaintiff and defense lawyers in Employment lawsuits.

More information

What to Expect When You re Expecting A Lawsuit

What to Expect When You re Expecting A Lawsuit What to Expect When You re Expecting A Lawsuit Jennifer G. Hall Meadowbrook Office Park 4268 I-55 North Jackson, MS 39211 601.351.2483 jhall@bakerdonelson.com What can Trigger a Lawsuit? Anything and everything

More information

Injury Case Roadmap. The Legal Process For Personal Injury Cases. By Christopher M. Davis, Attorney at Law

Injury Case Roadmap. The Legal Process For Personal Injury Cases. By Christopher M. Davis, Attorney at Law Injury Case Roadmap The Legal Process For Personal Injury Cases By Christopher M. Davis, Attorney at Law Davis Law Group, P.S. 2101 Fourth Avenue Suite 630 Seattle, WA 98121 206-727-4000 Davis Law Group,

More information

Case 5:10-cv-00206-MTT Document 18 Filed 02/10/11 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF GEORGIA MACON DIVISION

Case 5:10-cv-00206-MTT Document 18 Filed 02/10/11 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF GEORGIA MACON DIVISION Case 5:10-cv-00206-MTT Document 18 Filed 02/10/11 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF GEORGIA MACON DIVISION SARAH M. STALVEY, Plaintiff, v. CIVIL ACTION NO. 5:10-CV-206

More information

IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA APPELLATE DIVISION

IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA APPELLATE DIVISION County Civil Court: INSURANCE Personal Injury Protection Policy language stating that any amounts payable under this coverage shall be subject to any and all limitations including, but not limited to,

More information

GLEN A. SMITH DARRELL GILL, D.O., ET AL.

GLEN A. SMITH DARRELL GILL, D.O., ET AL. [Cite as Smith v. Gill, 2010-Ohio-4012.] Court of Appeals of Ohio EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA JOURNAL ENTRY AND OPINION No. 93985 GLEN A. SMITH PLAINTIFF-APPELLANT vs. DARRELL GILL, D.O.,

More information

How to Select a Lawyer by J. Sherrod Taylor

How to Select a Lawyer by J. Sherrod Taylor How to Select a Lawyer by J. Sherrod Taylor Persons with traumatic brain injury (TBI) and their families must make many important decisions in the early days following injury. One significant decision-that

More information

DEFENSES AVAILABLE TO PUBLIC ENTITIES & MUNICIPALITIES

DEFENSES AVAILABLE TO PUBLIC ENTITIES & MUNICIPALITIES DEFENSES AVAILABLE TO PUBLIC ENTITIES & MUNICIPALITIES 2015 Annual PARMA CONFERENCE February 8-11, 2015 Disneyland Conference Center Anaheim, California Caryn Siebert President/CEO Carl Warren & Company

More information

VIRGINIA ACTS OF ASSEMBLY -- 2015 SESSION

VIRGINIA ACTS OF ASSEMBLY -- 2015 SESSION VIRGINIA ACTS OF ASSEMBLY -- 2015 SESSION CHAPTER 585 An Act to amend and reenact 38.2-2206 of the Code of Virginia and to amend the Code of Virginia by adding in Article 7 of Chapter 3 of Title 8.01 a

More information

2:08-cv-12533-DPH-PJK Doc # 67 Filed 03/26/13 Pg 1 of 7 Pg ID 2147 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

2:08-cv-12533-DPH-PJK Doc # 67 Filed 03/26/13 Pg 1 of 7 Pg ID 2147 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION 2:08-cv-12533-DPH-PJK Doc # 67 Filed 03/26/13 Pg 1 of 7 Pg ID 2147 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION OLD REPUBLIC INSURANCE COMPANY, v. Plaintiff, MICHIGAN CATASTROPHIC

More information

CHAPTER 7 NURSING LIABILITY INSURANCE

CHAPTER 7 NURSING LIABILITY INSURANCE CHAPTER 7 NURSING LIABILITY INSURANCE We have all read many articles on and heard seminar speakers advocate why nurses should not buy professional liability insurance. However, in our opinion, there are

More information

Florida Workers' Compensation Depositions

Florida Workers' Compensation Depositions DENNIS A. PALSO workers compensation board certified DENNIS A. PALSO, P.A. ATTORNEY AT LAW Gateway Pines Executive Park 710-94 th Avenue North Suite 309 St. Petersburg, Florida 33702 Telephone (727) 578-5911

More information

Alternative Burdens May Come With Alternative Causes

Alternative Burdens May Come With Alternative Causes Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com Alternative Burdens May Come With Alternative Causes

More information

TOUGH QUESTIONS: Questions the Insurance Adjustors Don t Want You to Ask

TOUGH QUESTIONS: Questions the Insurance Adjustors Don t Want You to Ask : Questions the Insurance Adjustors Don t Want You to Ask BY EDDIE E. FARAH & CHARLIE E. FARAH, ATTORNEYS AT LAW ...the average total payout on claims that have an attorney is 3-1/2 times greater than

More information

CAUSE NO. 02-01125-J CHARLES DURHAM IN THE 191ST DISTRICT COURT LARVAN PERAILTA DALLAS COUNTY, TEXAS PLAINTIFF S MOTION TO RECOVER EXPENSES OF PROOF

CAUSE NO. 02-01125-J CHARLES DURHAM IN THE 191ST DISTRICT COURT LARVAN PERAILTA DALLAS COUNTY, TEXAS PLAINTIFF S MOTION TO RECOVER EXPENSES OF PROOF CAUSE NO. 02-01125-J CHARLES DURHAM IN THE 191ST DISTRICT COURT VS. LARVAN PERAILTA DALLAS COUNTY, TEXAS PLAINTIFF S MOTION TO RECOVER EXPENSES OF PROOF TO THE HONORABLE COURT: Comes Now, Charles Durham,

More information

Enrolled Copy H.B. 287

Enrolled Copy H.B. 287 Enrolled Copy H.B. 287 1 ARBITRATION FOR DOG BITES AMENDMENTS 2 2014 GENERAL SESSION 3 STATE OF UTAH 4 Chief Sponsor: LaVar Christensen 5 Senate Sponsor: John L. Valentine 6 7 LONG TITLE 8 General Description:

More information

Examining Elements to Prepare the Pediatric Practitioner

Examining Elements to Prepare the Pediatric Practitioner Mock Trial Examining Elements to Prepare the Pediatric Practitioner Brian G. Wilhelmi M.D./J.D., Eric V. Jackson M.D./M.B.A., Robert S. Greenberg M.D., Brian J. McNamara J.D. 1 Educational Objectives Upon

More information

Table of Contents. Glossary 4. What is a Personal Injury Case? 6. What Would My Case be Worth? 8. How Do You Prove a Claim? 10

Table of Contents. Glossary 4. What is a Personal Injury Case? 6. What Would My Case be Worth? 8. How Do You Prove a Claim? 10 Personal Injury Personal injury accidents happen all the time. From sidewalk cracks to car accidents, when people are injured, the question of who is legally and financially responsible is inevitably asked.

More information

****************************************************** The officially released date that appears near the beginning of each opinion is the date the

****************************************************** The officially released date that appears near the beginning of each opinion is the date the ****************************************************** The officially released date that appears near the beginning of each opinion is the date the opinion will be published in the Connecticut Law Journal

More information

Health Law Update By: Roger R. Clayton, Mark D. Hansen, and J. Matthew Thompson Heyl, Royster, Voelker & Allen, P.C., Peoria

Health Law Update By: Roger R. Clayton, Mark D. Hansen, and J. Matthew Thompson Heyl, Royster, Voelker & Allen, P.C., Peoria Illinois Association of Defense Trial Counsel Springfield, Illinois www.iadtc.org 800-232-0169 IDC Quarterly Volume 24, Number 1 (24.1.62) Health Law Update By: Roger R. Clayton, Mark D. Hansen, and J.

More information

Fridman v. Safeco Insurance Co., 41 Fla. Law Weekly S62 (Fla. February 25, 2016):

Fridman v. Safeco Insurance Co., 41 Fla. Law Weekly S62 (Fla. February 25, 2016): Clark Fountain welcomes referrals of personal injury, products liability, medical malpractice and other cases that require extensive time and resources. We handle cases throughout the state and across

More information

TORT AND INSURANCE LAW REPORTER. Informal Discovery Interviews Between Defense Attorneys and Plaintiff's Treating Physicians

TORT AND INSURANCE LAW REPORTER. Informal Discovery Interviews Between Defense Attorneys and Plaintiff's Treating Physicians This article originally appeared in The Colorado Lawyer, Vol. 25, No. 26, June 1996. by Jeffrey R. Pilkington TORT AND INSURANCE LAW REPORTER Informal Discovery Interviews Between Defense Attorneys and

More information

What Happens Next? By Ross A. Jurewitz Injury Accident Attorney, Jurewitz Law Group. Tel: 619-233-5020 Toll Free: 888-233-5020 contact@jurewitz.

What Happens Next? By Ross A. Jurewitz Injury Accident Attorney, Jurewitz Law Group. Tel: 619-233-5020 Toll Free: 888-233-5020 contact@jurewitz. What Happens Next? The Legal Process Roadmap for Personal Injury Cases By Ross A. Jurewitz Injury Accident Attorney, Jurewitz Law Group Jurewitz Law Group 600 B Street Suite 1550 San Diego, CA 92101 Tel:

More information

One Third Contingent Fee Agreement with Waiver of Sliding Scale

One Third Contingent Fee Agreement with Waiver of Sliding Scale Appendix II One Third Contingent Fee Agreement with Waiver of Sliding Scale, 2008 NAME OF CLIENT: DATE OF INJURY: JACOBS, GRUDBERG, BELT, DOW & KATZ P.C. ATTORNEY CONTINGENT FEE AGREEMENT WITH WAIVER OF

More information