CALIFORNIA TORT FORMS FROM EXPERT LITIGATORS (1st Edition) July 2015 TABLE OF CONTENTS File Name Book Section Title CH01 Chapter 1 Animals 01-006 1.6 Sample Client Authorization to Release Medical 01-007 1.7 Sample Client Authorization to Release Animal Control or Police Report 01-008 1.8 Sample Request for Animal Control or Police Report 01-009 1.9 Sample Initial Letter to Defendant Regarding Dog Bite and Requesting Insurance 01-010 1.10 Sample Demand Letter Requesting Compensation for Personal Injuries 01-014 1.14 Sample Plaintiff s Initial Special Interrogatories 01-015 1.15 Sample Plaintiff s Initial Demand for Inspection 01-016 1.16 Sample Plaintiff s Initial Demand for Production 01-017 1.17 Sample Plaintiff s Mediation Brief Personal Injuries and Property Damage in Dog Bite 01-018 1.18 Sample Motion in Limine by Plaintiff Personal Injuries and Property Damage in Dog Bite With Memorandum and Proposed Order 01-019 1.19 Sample Key Jury Instructions for Plaintiff Personal Injuries and Property Damage in Dog Bite 01-021 1.21 Sample Defendant s Initial Set of Special Interrogatories 01-022 1.22 Sample Defendant s Initial Demand for Production of Documents 01-023 1.23 Sample Defendant s Mediation Brief Personal Injuries and Property Damage in Dog Bite 01-024 1.24 Sample Motion in Limine by Defendant Personal Injuries and Property Damage in Dog Bite 01-025 1.25 Sample Key Jury Instructions for Defendant CH02 Chapter 2 Automobiles 02-011 2.11 Sample Client Authorization to Release Medical
02-012 2.12 Sample Request for Client s Billing and Medical Records 02-013 2.13 Sample Request for Police Report With Attached Client Authorization 02-014 2.14 Sample Letter Advising Defendant of Client s Representation by Attorney 02-015 2.15 Sample Letter Advising Defendant s of Client s Representation by Attorney 02-016 2.16 Sample Settlement Demand Letter to Defendant s 02-019 2.19 Sample Demand for Inspection of Defendant s Automobile 02-020 2.20 Sample Plaintiff s Initial Demand for Production 02-021 2.21 Sample Plaintiff s Initial Requests for Admission 02-022 2.22 Sample Plaintiff s Motion in Limine 02-023 2.23 Sample Key Jury Instructions for Plaintiff Personal Injuries and Property Damage in Automobile Collision 02-025 2.25 Sample Defendant s Initial Special Interrogatories 02-026 2.26 Sample Defendant s Initial Demand for Production 02-028 2.28 Sample Notice to Plaintiff of Taking Deposition 02-029 2.29 Sample Letter by Defendant Offering to Settle 02-030 2.30 Sample Key Jury Instructions for Defendant Personal Injuries and Property Damage in Automobile Collision CH03 Chapter 3 Carriers 03-010 3.10 Sample Client Authorization to Release Medical 03-011 3.11 Sample Initial Letter to Defendant Regarding Plaintiff s Injury and Requesting Insurance 03-012 3.12 Sample Letter of Representation to Defendant s 03-014 3.14 Sample Plaintiff s Initial Special Interrogatories Personal Injuries in Carrier Liability 03-015 3.15 Sample Plaintiff s Initial Demand for Production Personal Injuries in Carrier Liability 03-016 3.16 Sample Plaintiff s Initial Demand for Inspection Personal Injuries in Carrier Liability 03-017 3.17 Sample Plaintiff s Letter Proposing Settlement Personal Injuries in Carrier Liability 03-018 3.18 Sample Key Jury Instructions for Plaintiff Personal Injuries in Carrier Liability 03-019 3.19 Sample Letter by Defendant Requesting Additional Time to Answer or Otherwise Plead in Carrier Liability
03-021 3.21 Sample Defendant s Initial Set of Special Interrogatories Personal Injuries in Carrier Liability 03-022 3.22 Sample Defendant s Initial Demand for Production of Documents Personal Injuries in Carrier Liability 03-023 3.23 Sample Notice to Plaintiff of Taking Deposition 03-024 3.24 Sample Defendant s Letter Proposing Settlement Personal Injuries in Carrier Liability 03-025 3.25 Sample Defendant s Demand for Exchange of Expert Witness 03-026 3.26 Sample Motion in Limine by Defendant With Proposed Order Personal Injuries in Carrier Liability 03-027 3.27 Sample Key Jury Instructions for Defendant Personal Injuries in Carrier Liability CH04 Chapter 4 Construction Liability 04-010 4.10 Sample Release of Client s Health From Provider 04-011 4.11 Sample Plaintiff s Cal/OSHA Report Request 04-012 4.12 Sample Complaint for Damages in Construction 04-013 4.13 Sample Plaintiff s Initial Demand for Production of Documents 04-014 4.14 Sample Plaintiff s Initial Requests for Admission 04-015 4.15 Sample Plaintiff s Initial Demand for Site Inspection 04-016 4.16 Sample Plaintiff s Statement of Damages 04-017 4.17 Sample Plaintiff s Motion in Limine Regarding Cal/OSHA Citations and Conclusions 04-018 4.18 Sample Plaintiff s Key Jury Instructions 04-019 4.19 Sample Answer to Complaint for Damages in Construction 04-020 4.20 Sample Defendant s Initial Special Interrogatories 04-021 4.21 Sample Defendant s Notice of Taking Deposition 04-022 4.22 Sample Defendant s Mediation Brief 04-023 4.23 Sample Defendant s Key Jury Instructions CH05 Chapter 5 Governmental Liability 05-013 5.13 Sample Application for Leave to File Late Claim 05-014 5.14 Sample Petition for Relief From Claim Requirement 05-015 5.15 Sample Complaint for Damages for Personal Injury Dangerous Condition of Public Property 05-016 5.16 Sample Plaintiff s Initial Demand for Production 05-017 5.17 Sample Plaintiff s Initial Requests for Admission 05-018 5.18 Sample Key Jury Instructions for Plaintiff Dangerous Condition of Public Property 05-020 5.20 Sample Demurrer to Complaint for Damages Alleging Governmental Liability
05-021 5.21 Sample Memorandum of Points and Authorities in Support of Demurrer to Complaint 05-022 5.22 Sample Notice of Hearing on Demurrer to Complaint 05-024 5.24 Sample Defendant s Initial Demand for Production of Documents 05-025 5.25 Sample Notice to Plaintiff of Taking Deposition 05-026 5.26 Sample Key Jury Instructions for Defendant Dangerous Condition of Public Property CH06 Chapter 6 Medical Malpractice 06-013 6.13 Sample Client Authorization to Release Medical 06-014 6.14 Sample Notice of Claim ( 90-Day Letter ) to Health Care Provider 06-015 6.15 Sample Letter of Representation to Defendant s 06-016 6.16 Sample Demand Letter Requesting Compensation for Personal Injuries and Proposing Settlement 06-017 6.17 Sample Complaint for Damages Personal Injuries Based on Medical Negligence 06-018 6.18 Sample Plaintiff s Memorandum Opposing Defendant s Demurrer 06-019 6.19 Sample Plaintiff s Initial Special Interrogatories Personal Injuries in Medical Negligence 06-020 6.20 Sample Plaintiff s Notice of Taking Deposition 06-021 6.21 Sample Plaintiff s Motion in Limine 06-022 6.22 Sample Key Jury Instructions for Plaintiff in Medical Negligence 06-023 6.23 Sample Notice of Demurrer and Demurrer to Complaint for Damages in Medical Negligence 06-024 6.24 Sample Answer to Complaint for Damages in Medical Negligence 06-025 6.25 Sample Defendant s Initial Demand for Production of Documents in Medical Negligence 06-026 6.26 Sample Defendant s Follow-Up Pretrial Demand for Production of Documents in Medical Negligence 06-027 6.27 Sample Defendant s Initial Special Interrogatories in Medical Negligence 06-028 6.28 Sample Defendant s Initial Request for Admissions in Medical Negligence 06-029 6.29 Sample Defendant s Notice of Taking Deposition With Demand for Documents and Things 06-030 6.30 Sample Key Jury Instructions for Defendant in Medical Negligence CH07 Chapter 7 Premises Liability
07-015 7.15 Sample Client Authorization to Release Medical 07-016 7.16 Sample Initial Letter to Defendant Regarding Plaintiff s Injury and Requesting Insurance 07-017 7.17 Sample Letter of Representation to Defendant s 07-018 7.18 Sample Demand Letter Requesting Compensation for Personal Injuries and Proposing Settlement 07-020 7.20 Sample Plaintiff s Initial Special Interrogatories Personal Injuries in Premises Liability 07-021 7.21 Sample Plaintiff s Initial Demand for Inspection Personal Injuries in Premises Liability 07-022 7.22 Sample Plaintiff s Initial Demand for Production Personal Injuries in Premises Liability 07-023 7.23 Sample Plaintiff s Mediation Brief Personal Injuries in Premises Liability 07-024 7.24 Sample Motion in Limine by Plaintiff Personal Injuries in Premises Liability With Memorandum and Proposed Order 07-025 7.25 Sample Key Jury Instructions for Plaintiff Personal Injuries in Premises Liability 07-027 7.27 Sample Defendant s Initial Set of Special Interrogatories Personal Injuries in Premises Liability 07-028 7.28 Sample Defendant s Initial Demand for Production of Documents Personal Injuries in Premises Liability 07-029 7.29 Sample Notice to Plaintiff of Taking Deposition 07-030 7.30 Sample Letter by Defendant Offering to Settle 07-031 7.31 Sample Defendant s Demand for Exchange of Expert Witness 07-032 7.32 Sample Defendant s Mediation Brief Personal Injuries in Premises Liability 07-033 7.33 Sample Motion in Limine by Defendant Personal Injuries in Premises Liability 07-034 7.34 Sample Key Jury Instructions for Defendant Personal Injuries in Premises Liability CH08 Chapter 8 Product Liability 08-021 8.21 Sample Client Authorization to Release Medical 08-022 8.22 Sample Complaint for Damages Personal Injuries in Product Liability 08-023 8.23 Sample Plaintiff s Initial Special Interrogatories to Defendant in Product Liability
08-024 8.24 Sample Plaintiff s Initial Demand to Defendant for Production in Product Liability 08-025 8.25 Sample Plaintiff s Letter Proposing Settlement Personal Injuries in Product Liability 08-026 8.26 Sample Plaintiff s Memorandum Opposing Defendant s Motion in Limine 08-027 8.27 Sample Key Jury Instructions for Plaintiff Personal Injuries in Product Liability 08-028 8.28 Sample Answer to Complaint for Damages Personal Injuries in Product Liability 08-029 8.29 Sample Notice to Plaintiff of Taking Deposition 08-030 8.30 Sample Defendant s Initial Demand for Inspection Personal Injuries in Product Liability 08-031 8.31 Sample Defendant s Letter Proposing Settlement Personal Injuries in Product Liability 08-032 8.32 Sample Defendant s Demand for Exchange of Expert Witness 08-033 8.33 Sample Key Jury Instructions for Defendant Personal Injuries in Product Liability