General Case Work
* Review complaint and determine whether state court case can be removed to federal court based on diversity or federal
question. Draft necessary motion and pleadings for removal.
* Prepare necessary release forms to obtain medical records, employment records, military records, and Social Security
records. Arrange signing of forms through plaintiffs' counsel and obtain certified copies of all records.
* Organize, review, and summarize plaintiffs' responses to discovery requests along with all documents received from
outside sources. Note exposure/diagnosis dates.
* Prepare analysis and/or charts evidencing product exposure. Alert attorneys to any statute of limitations defenses
or other defenses.
* Schedule independent medical examination, if necessary, and act as liaison between medical expert and trial team
to ensure that all information, documentation, x-rays and pathology materials relating to plaintiffs are properly organized
* Supervise nurse/consultant on various projects.
* Prepare summary of factual information for attorneys use to evaluate settlement value of case or to prepare for
depositions and/or trial.
* When appropriate, prepare deposition notices or affidavits in lieu of scheduling depositions.
* Arrange for expedited trial and "perpetuated" deposition testimony for dying plaintiffs.