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Then I can review it, the documents and reword their responses as needed. The way we do it now is so time consuming and it’s not easy for the clients either. It’s all an unorganized mess when we get their answers and documents. I know that’s just how it’s going to be with some clients though no matter how easy you make it for them. I am helping the firm with efficiency so this is a work in progress.
Are you on Plaintiff or the Defense side? I would think for Plaintiff, you would send them a copy and go over them one by one with them. It's also helpful, for your own knowledge, to request complete certified records for all providers. By not doing that and only focusing on the accident, if you do PI, you are likely to miss stuff. I can't tell you how many good things have been found by this that Plaintiff had no idea about. Once that's complete, they should review and sign. Depending on your Defendant, it depends on how and what you ask for. We ask for everything under the sun, so we decide what's responsive.
I think the paperwork is rather intimidating to non-lawyers, clients would freak when they read some of the questions. I would go through interrogatories and mark each one that they had to answer, doctors for past ten years not related to accident, residences, divorces, work history, personal things like that, that we could not get from records we have. Would always give them a two week deadline and then follow up accordingly. Same with RTP, if you have it in your possession, marriage license, birth certificates, insurance cards, etc., fine, if not, don’t worry about it. We did allow individual authorizations to opposing counsel but only if records were released to both parties at the same time.
Subject Expert
Well, what I do is make certain the firm has received all the documents.
2. If not, I tell the client, politely but to the point, "Look, if you do not give us the requested documents to give to OC, well, then they could ask the court to sanction you and the cost, IF the court does sanction you (make certain "you" in it) then you will be paying a hefty price as high as $5000.00 or as low as $1500.00." We have let you know the consequences. We make certain it is in writing. Since your attorneys are a bit old School (which can be good sometimes), then have it written up in the contract, where they are to initial every paragraph, every page. It's CYA all the way. We always have to hold the clients hands. It is part of the process.
I remember a client came to our office and he flat out did not want to cooperate because he was in fear (and he was arrogant about it) that his sister would get all the money (she was the original client). My attorney he was listening through the wall and emailed me and told me to inform him that it doesn't matter because if he won't hand over the documents it's fine, the statute of limitations on the case will run out in 2 weeks anyway. So, if he wanted to join in the suit then he needed to sign the contract and produce whatever documents he has.
I honestly couldn't help but laugh, it took almost everything within me to keep from bursting into laughter with the clients look on his face after I told me. That was personal injury.
Now, in family law (which is where I'm at now) is, we send the clients the documents by email (or they can come in and get the Request) but we give them a deadline to have it to us by (2 weeks before the actual deadline to OC). If they give more later, we supplement.
While waiting on the client to bring in all their documents I go ahead and do the response objections. Seriously, some of the stuff that's being asked is unnecessary. So, my favorite objection is the "fishing expedition" I LOVE IT.