Library of Georgia Personal Injury Law Forms with CD-ROM (Print and Online)

Transcription

1 Brochure More information from Library of Georgia Personal Injury Law Forms with CD-ROM (Print and Online) Description: As much as victims need advocates, advocates need tools. When representing a plaintiff in a personal injury or wrongful death case in Georgia, lawyers can rely on Library of Georgia Personal Injury Forms from the library of Fried Rogers Goldberg LLC. Why not start with the letters, pleadings and other forms crafted by a firm that has recovered more than $200 million in settlements and verdicts for its clients? Library of Georgia Personal Injury Forms contains nearly 250 practice-oriented forms and sample letters from the library of plaintiffs' personal injury boutique Fried Rogers Goldberg LLC. The anthology includes a CD-Rom linking to MS Word forms that can be customized for each firm and modified for each case. Each of the 16 chapters is preceded by a summary clarifying when its editor, Michael L. Goldberg, uses a specific form or document. And a detailed checklist can be found at the end of every chapter. Among the myriad topics: notification of representation, preserving evidence, investigation of liability, proving injuries and damages, complaints, discovery, motions, responses, depositions, trial and resolution of claims. Editor Michael L. Goldberg, a frequent speaker at legal seminars, is also author of three editions of Understanding Vehicle Claims, a legal treatise on trucking law. Contents: CHAPTER 1--DEALING WITH POTENTIAL CLIENTS AND SIGNING UP THE CASE New Client Information Sheet Fee Agreement Contract Letter to Client Enclosing Fee Agreement Contract Medical Authorization to Be Signed by Client Employment Records Authorization to Be Signed by Client Letter to Client: Investigating Claim Before Deciding Whether to Take Case Authorization to Transfer File From Previous Attorney Letter to Previous Attorney Requesting Client's File Letter to Client: Co-Counsel Agreement Letter to Referring Attorney Memorializing Co-Counsel Agreement Thank-You Letter to Attorney for Referral Thank-You Letter to Non-Attorney for Referral Rejection Letter: Personal Injury Case Rejection Letter: Medical Malpractice Case Conflict Waiver Chapter 1 Checklist

2 CHAPTER 2-- NOTIFICATION OF REPRESENTATION AND PRESERVING EVIDENCE Letter of Representation to Defendant Requesting Insurance Information Affidavit for Requesting Policy Limits Letter of Representation to Insurer Requesting Policy Limits Ante Litem Notice to City Ante Litem Notice to County Notice for State Tort Claims Act General Spoliation Letter Trucking Spoliation Letter Law Enforcement Misconduct Spoliation Letter Escalator/Elevator Spoliation Letter Nursing Home Spoliation Letter Spoliation Letter to Preserve Surveillance Tapes Letter Placing UM Insurer on Notice of Claim Letter Placing Clients Insurer on Notice of Medpay Claim Chapter 2 Checklist CHAPTER 3--INVESTIGATION OF LIABILITY Letter to Insurer Requesting Clients Recorded Statement Letter Requesting Accident Report from Police Open Records Act Request to Police for Entire Investigative File Open Records Act Request for 911 Tapes/CAD Report Letter Requesting Certified Copy of Guilty Plea Letter to GBI Requesting Autopsy Report Letter to GBI Requesting Toxicology Reports Freedom of Information Act Request to Federal Governmental Entity Freedom of Information Act Request to Federal Motor Carrier Safety Administration Open Records Act Request to MARTA for Elevator/Escalator Incident Open Records Act Request to Department of Human Resources

3 3-012 Open Records Act Request to Animal Control Open Records Act Request to Police for Criminal History of Property Open Records Act Request to Internal Affairs/Police Department for Excessive Force Open Records Act Request to Department of Labor Chapter 3 Checklist CHAPTER 4--PROVING YOUR CLIENTS INJURIES AND DAMAGES Letter to Client Requesting Damages Information in Personal Injury Case Letter to Client Requesting Damages Information in Wrongful Death Case Letter to Client Requesting Status of Medical Treatment Letter to Employer with Wage Loss Verification Wage Loss Verification to Employer for Personal Injury Claim Request for Tax Returns to Internal Revenue Service IRS Form 4506 for Requesting Tax Returns Request for Clients Personnel File from Employer Request for Clients Medical Records Request for Clients Pharmacy Records Request for Clients Medical Bills Request for Death Certificate Letter Following Up on Request for Medical Records or Bills Letter Requesting Updated Medical Records Request for Diagnostic Films Medical Expense Summary Letter Requesting Military Service Records Military Service Records Form Chapter 4 Checklist CHAPTER 5--COMPLAINTS Automobile Accident: Two Vehicles Automobile Accident: Passenger

4 5-003 Automobile Accident: Pedestrian Automobile Accident: Family Purpose Doctrine Automobile Accident: John Doe Wrongful Death Section of Complaint Punitive Damages Section of Complaint Employer Liability Section of Complaint Trucking Accident Premises Liability: Slip and Fall, Foreign Substance Premises Liability: Slip and Fall, Static Defect Premises Liability: Negligent Security Escalator/Elevator Accident Dog Bite False Arrest by Premises Owner Employee Assault on Premises Excessive Force Police Misconduct Medical Malpractice: Physician Medical Malpractice Affidavit Medical Malpractice: Hospital Assisted Living Center Dram Shop Liability Products Liability Georgia DOT/State Tort Claims Act Bad Faith/Negligent Failure to Settle Chapter 5 Checklist CHAPTER 6 --FILING AND SERVICE OF THE COMPLAINT Summons Letter to Clerk Enclosing Complaint and Service on Defendant Letter to Clerk Enclosing Complaint and Returning Original for Service Letter to Sheriff to Serve Complaint

5 6-005 Motion for Appointment of Private Process Server to Serve Complaint Order Appointing Private Process Server Affidavit of Service for Private Process Server Letter to Private Process Server to Serve Complaint and Discovery Letter to Secretary of State with Complaint by Non-Resident Motorist Statute Service Affidavit of Compliance for Non-Resident Motorist Statute Service Certified Letter to Defendant Under Non-Resident Motorist Statute Acknowledgment of Service Letter to Opposing Counsel Enclosing Acknowledgment of Service Form Motion for Substituted Service of Process by Publication Affidavit of Attorney Supporting Motion for Service by Publication Order for Service by Publication Certified Letter to Insurer Enclosing Copy of Complaint Chapter 6 Checklist CHAPTER 7--DISCOVERY: INTERROGATORIES, REQUEST FOR DOCUMENTS AND REQUEST FOR ADMISSIONS Auto Accident Auto Accident: Family Purpose Trucking Collision Premises Liability: Fall Case Premises Liability: Negligent Security Escalator/Elevator Accident Dog Bite False Arrest by Premises Owner Employee Assault on Premises Employer Liability Excessive Force Police Misconduct Medical Malpractice: Physician Medical Malpractice: Hospital Assisted Living Center Dram Shop Liability Products Liability

6 7-017 Georgia DOT/State Tort Claims Act Bad Faith/Negligent Failure to Settle Jurisdiction over the Defendant Underinsured/Uninsured Motorist Insurer Direct Action Against Truck Insurer Liability of Employer for Employees Conduct Liability of Defendant for Collision Certificate of Service of Discovery Chapter 7 Checklist CHAPTER 8--ANSWERING DISCOVERY FROM THE DEFENDANT Letter to Client Requesting Information for Discovery Responses Letter to Opposing Counsel Confirming Extension Time to Respond to Discovery Response to Interrogatories Verification of Interrogatory Responses for Client Signature Response to Request for Production of Documents Response to Request for Admissions Supplemental Discovery Responses Chapter 8 Checklist CHAPTER 9--COMPELLING RESPONSES TO DISCOVERY Letter to Opposing Counsel Requesting Overdue Discovery Responses Letter to Opposing Counsel Requesting Complete Discovery Responses Good Faith Letter to Opposing Counsel Under Rule Motion to Compel Discovery Responses Brief in Support of Motion to Compel Discovery Responses Motion to Strike Defendants Answer for Failing to Respond to Discovery Brief in Support to Motion to Strike Defendants Answer for Failing to Respond to Discovery Letter to Opposing Counsel Requesting Verification to Interrogatory Responses

7 9-009 Chapter 9 Checklist CHAPTER 10--DEPOSITIONS Letter to Client Confirming Deposition Letter to Opposing Counsel Confirming Deposition Notice of Deposition of Witness or Party for Discovery Notice of Videotaped Deposition Letter to Doctor Confirming Deposition Notice of Evidentiary Doctor Deposition Notice of Expert Deposition for Discovery Letter to Opposing Counsel Requesting Deposition of Corporate Representative Notice of Corporate Representative Deposition for Discovery Notice of Corporate Representative Deposition on Financial Issues Letter to Witness Enclosing Subpoena for Deposition Amended Deposition Notice Chapter 10 Checklist CHAPTER 11--OTHER DOCUMENTS RELATED TO DISCOVERY Request for Production of Documents to Non-Party Request for Cellphone Records Letter Enclosing Subpoena for Driving Record Joint Motion to Extend Discovery Period Order Extending Discovery Period Consent Scheduling Order Consent Protective Order Chapter 11 Checklist CHAPTER 12--MOTIONS AND RESPONSES Motion to Add Party Defendant Brief in Support of Motion to Add Party Defendant

8 Motion for Default Judgment Certificate of Default Order Entering Default Judgment Motion to Enforce Settlement Consent Motion to Dismiss Less Than All Parties Order Dismissing Less Than All Parties Consent Motion for Continuance from Trial Calendar Brief in Response to Defendants Motion for Summary Judgment Response to Defendants Statement of Material Facts Plaintiffs Statement of Material Facts to Which There Exists a Genuine Issue to Be Tried Theory of Recovery Affidavit of Witness Notice of Filing Original Discovery Request to File Original Discovery Notice of Hearing Stipulation Extending Time to Respond to Motion Withdrawal of Motion Chapter 12 Checklist CHAPTER 13--LITIGATION LETTERS Letter to Client Enclosing Medical Authorization for Defendant Letter to Opposing Counsel Enclosing Medical Authorization Executed by Client Letter to Opposing Counsel Requesting Records Obtained From Non-Parties Letter to Client Explaining Independent Medical Examination Letter to Expert to Review Records Letter to Witness Requesting a Recorded Statement Letter to Judge Enclosing Proposed Order Chapter 13 Checklist CHAPTER 14--TRIAL

9 Letter to Clerk Stipulating Case to Trial Calendar Letter to Client Confirming Trial Date Letter to Witness Enclosing Subpoena and Confirming Trial Date Letter to Expert Confirming Trial Date Consolidated Pre-Trial Order Motions in Limine Brief in Support of Motions in Limine Letter to Opposing Counsel Enclosing Subpoena of Party Order Allowing Video Equipment into Courtroom Request to Charge General Verdict Form Chapter 14 Checklist CHAPTER 15--SETTLEMENT AND RESOLUTION OF CLAIMS Comprehensive Demand Letter Unliquidated Damages Demand Introduction Underinsured Motorist Coverage Demand Introduction Policy Limits Demand Introduction Request for Affidavit of No Additional Insurance Demand Introduction Affidavit of No Additional Insurance Offer of Settlement Certificate of Service of Offer of Settlement Consent Judgment Assignment of Bad Faith Claim Against Insurer Letter to Opposing Counsel Confirming Mediation Letter to Client Explaining Mediation Letter to Opposing Counsel Confirming Settlement W-9 Tax Identification Form Settlement Statement Letter to Health Insurer About Possible Lien

10 Letter to Workers Compensation Carrier Denying Lien Letter to Medicare Inquiring About Lien Medicare Proof of Representation Form Letter to Medicaid Inquiring About Lien Letter to Lienholder Enclosing Compromised Payment of Lien Letter to Referring Attorney Enclosing Fee Chapter 15 Checklist CHAPTER 16--ADMINISTRATIVE FORMS Change of Address Leave of Absence Conflict Letter Letter to Client Asserting Attorney Lien Notice to Defendant/Insurer of Attorney Lien Letter to Client Providing Notice of Withdrawal Notice of Withdrawal Motion to Withdraw as Counsel Order Granting Motion to Withdraw as Counsel Notice of Appearance of Counsel Substitution of Counsel Chapter 16 Checklist Ordering: Order Online - Order by Fax - using the form below Order by Post - print the order form below and send to Research and Markets, Guinness Centre, Taylors Lane, Dublin 8, Ireland.

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