CALIFORNIA TORT FORMS FROM EXPERT LITIGATORS (1st Edition) July 2015 TABLE OF CONTENTS

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1 CALIFORNIA TORT FORMS FROM EXPERT LITIGATORS (1st Edition) July 2015 TABLE OF CONTENTS File Name Book Section Title CH01 Chapter 1 Animals Sample Client Authorization to Release Medical Sample Client Authorization to Release Animal Control or Police Report Sample Request for Animal Control or Police Report Sample Initial Letter to Defendant Regarding Dog Bite and Requesting Insurance Sample Demand Letter Requesting Compensation for Personal Injuries Sample Plaintiff s Initial Special Interrogatories Sample Plaintiff s Initial Demand for Inspection Sample Plaintiff s Initial Demand for Production Sample Plaintiff s Mediation Brief Personal Injuries and Property Damage in Dog Bite Sample Motion in Limine by Plaintiff Personal Injuries and Property Damage in Dog Bite With Memorandum and Proposed Order Sample Key Jury Instructions for Plaintiff Personal Injuries and Property Damage in Dog Bite Sample Defendant s Initial Set of Special Interrogatories Sample Defendant s Initial Demand for Production of Documents Sample Defendant s Mediation Brief Personal Injuries and Property Damage in Dog Bite Sample Motion in Limine by Defendant Personal Injuries and Property Damage in Dog Bite Sample Key Jury Instructions for Defendant CH02 Chapter 2 Automobiles Sample Client Authorization to Release Medical

2 Sample Request for Client s Billing and Medical Records Sample Request for Police Report With Attached Client Authorization Sample Letter Advising Defendant of Client s Representation by Attorney Sample Letter Advising Defendant s of Client s Representation by Attorney Sample Settlement Demand Letter to Defendant s Sample Demand for Inspection of Defendant s Automobile Sample Plaintiff s Initial Demand for Production Sample Plaintiff s Initial Requests for Admission Sample Plaintiff s Motion in Limine Sample Key Jury Instructions for Plaintiff Personal Injuries and Property Damage in Automobile Collision Sample Defendant s Initial Special Interrogatories Sample Defendant s Initial Demand for Production Sample Notice to Plaintiff of Taking Deposition Sample Letter by Defendant Offering to Settle Sample Key Jury Instructions for Defendant Personal Injuries and Property Damage in Automobile Collision CH03 Chapter 3 Carriers Sample Client Authorization to Release Medical Sample Initial Letter to Defendant Regarding Plaintiff s Injury and Requesting Insurance Sample Letter of Representation to Defendant s Sample Plaintiff s Initial Special Interrogatories Personal Injuries in Carrier Liability Sample Plaintiff s Initial Demand for Production Personal Injuries in Carrier Liability Sample Plaintiff s Initial Demand for Inspection Personal Injuries in Carrier Liability Sample Plaintiff s Letter Proposing Settlement Personal Injuries in Carrier Liability Sample Key Jury Instructions for Plaintiff Personal Injuries in Carrier Liability Sample Letter by Defendant Requesting Additional Time to Answer or Otherwise Plead in Carrier Liability

3 Sample Defendant s Initial Set of Special Interrogatories Personal Injuries in Carrier Liability Sample Defendant s Initial Demand for Production of Documents Personal Injuries in Carrier Liability Sample Notice to Plaintiff of Taking Deposition Sample Defendant s Letter Proposing Settlement Personal Injuries in Carrier Liability Sample Defendant s Demand for Exchange of Expert Witness Sample Motion in Limine by Defendant With Proposed Order Personal Injuries in Carrier Liability Sample Key Jury Instructions for Defendant Personal Injuries in Carrier Liability CH04 Chapter 4 Construction Liability Sample Release of Client s Health From Provider Sample Plaintiff s Cal/OSHA Report Request Sample Complaint for Damages in Construction Sample Plaintiff s Initial Demand for Production of Documents Sample Plaintiff s Initial Requests for Admission Sample Plaintiff s Initial Demand for Site Inspection Sample Plaintiff s Statement of Damages Sample Plaintiff s Motion in Limine Regarding Cal/OSHA Citations and Conclusions Sample Plaintiff s Key Jury Instructions Sample Answer to Complaint for Damages in Construction Sample Defendant s Initial Special Interrogatories Sample Defendant s Notice of Taking Deposition Sample Defendant s Mediation Brief Sample Defendant s Key Jury Instructions CH05 Chapter 5 Governmental Liability Sample Application for Leave to File Late Claim Sample Petition for Relief From Claim Requirement Sample Complaint for Damages for Personal Injury Dangerous Condition of Public Property Sample Plaintiff s Initial Demand for Production Sample Plaintiff s Initial Requests for Admission Sample Key Jury Instructions for Plaintiff Dangerous Condition of Public Property Sample Demurrer to Complaint for Damages Alleging Governmental Liability

4 Sample Memorandum of Points and Authorities in Support of Demurrer to Complaint Sample Notice of Hearing on Demurrer to Complaint Sample Defendant s Initial Demand for Production of Documents Sample Notice to Plaintiff of Taking Deposition Sample Key Jury Instructions for Defendant Dangerous Condition of Public Property CH06 Chapter 6 Medical Malpractice Sample Client Authorization to Release Medical Sample Notice of Claim ( 90-Day Letter ) to Health Care Provider Sample Letter of Representation to Defendant s Sample Demand Letter Requesting Compensation for Personal Injuries and Proposing Settlement Sample Complaint for Damages Personal Injuries Based on Medical Negligence Sample Plaintiff s Memorandum Opposing Defendant s Demurrer Sample Plaintiff s Initial Special Interrogatories Personal Injuries in Medical Negligence Sample Plaintiff s Notice of Taking Deposition Sample Plaintiff s Motion in Limine Sample Key Jury Instructions for Plaintiff in Medical Negligence Sample Notice of Demurrer and Demurrer to Complaint for Damages in Medical Negligence Sample Answer to Complaint for Damages in Medical Negligence Sample Defendant s Initial Demand for Production of Documents in Medical Negligence Sample Defendant s Follow-Up Pretrial Demand for Production of Documents in Medical Negligence Sample Defendant s Initial Special Interrogatories in Medical Negligence Sample Defendant s Initial Request for Admissions in Medical Negligence Sample Defendant s Notice of Taking Deposition With Demand for Documents and Things Sample Key Jury Instructions for Defendant in Medical Negligence CH07 Chapter 7 Premises Liability

5 Sample Client Authorization to Release Medical Sample Initial Letter to Defendant Regarding Plaintiff s Injury and Requesting Insurance Sample Letter of Representation to Defendant s Sample Demand Letter Requesting Compensation for Personal Injuries and Proposing Settlement Sample Plaintiff s Initial Special Interrogatories Personal Injuries in Premises Liability Sample Plaintiff s Initial Demand for Inspection Personal Injuries in Premises Liability Sample Plaintiff s Initial Demand for Production Personal Injuries in Premises Liability Sample Plaintiff s Mediation Brief Personal Injuries in Premises Liability Sample Motion in Limine by Plaintiff Personal Injuries in Premises Liability With Memorandum and Proposed Order Sample Key Jury Instructions for Plaintiff Personal Injuries in Premises Liability Sample Defendant s Initial Set of Special Interrogatories Personal Injuries in Premises Liability Sample Defendant s Initial Demand for Production of Documents Personal Injuries in Premises Liability Sample Notice to Plaintiff of Taking Deposition Sample Letter by Defendant Offering to Settle Sample Defendant s Demand for Exchange of Expert Witness Sample Defendant s Mediation Brief Personal Injuries in Premises Liability Sample Motion in Limine by Defendant Personal Injuries in Premises Liability Sample Key Jury Instructions for Defendant Personal Injuries in Premises Liability CH08 Chapter 8 Product Liability Sample Client Authorization to Release Medical Sample Complaint for Damages Personal Injuries in Product Liability Sample Plaintiff s Initial Special Interrogatories to Defendant in Product Liability

6 Sample Plaintiff s Initial Demand to Defendant for Production in Product Liability Sample Plaintiff s Letter Proposing Settlement Personal Injuries in Product Liability Sample Plaintiff s Memorandum Opposing Defendant s Motion in Limine Sample Key Jury Instructions for Plaintiff Personal Injuries in Product Liability Sample Answer to Complaint for Damages Personal Injuries in Product Liability Sample Notice to Plaintiff of Taking Deposition Sample Defendant s Initial Demand for Inspection Personal Injuries in Product Liability Sample Defendant s Letter Proposing Settlement Personal Injuries in Product Liability Sample Defendant s Demand for Exchange of Expert Witness Sample Key Jury Instructions for Defendant Personal Injuries in Product Liability

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