When meeting with a possible personal injury client initially, instruct him to keep in constant contact with you with any pertinent case history. It is critical to start working on the file right away to best serve the plaintiff as well as to reinforce the importance of your services. Repeatedly admonish your client not to talk to anyone regarding the civil case except the authorities, without your express permission.

Your client must understand the importance of having the investigator thoroughly document the scene before they get repaired or begin clean up.

Any third party witnesses should be spoken to immediately. The accident scene should be inspected and photographed before anyone touches any important evidence. Your client must be instructed to retain clothing and any other personal items before the hospital destroys them. Injuries or markings of any sort are extremely important for photo evidence.

The plaintiff must be made to understand that the main responsibility of the insurance carrier is to minimize their financial damage, rather than being interested in the welfare of the injured party. The defendant is advised that he has 21 days to respond after the recorded date of service for the civil summons and complaint. The complaint is sent with two copies to the defendant, with instructions to provide a set to the appropriate insurance carrier. Make sure that all documented medical evidence is correct per complete agreement with the plaintiff. Allow yourself sufficient time to read everything over carefully. Don’t forget that the insurance carriers put much greater emphasis on the opinion of a certified physician, as opposed to a layman.

Keep stressing to the client both in correspondence and in conversation that you believe he has a very strong chance of winning this case, based on existing information. This illustrates the attorney’s difficulty in assessing the probable liability of the defendant when he is still scrambling to gather the much needed damage information.

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