Revised May 12, 2003

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					                                                           ATTACHMENT A

                                                THE AGREED-TO LITIGATION PLAN
                         The following provides a template for documenting the Agreed-to Litigation Plan (ATLP).

                               The ATLP should be marked as Privileged and Confidential



                Claims Professional:                                     Date:
                Lawyer:                                                  Version:
                Insured:                                                 Time Period of ATLP:
                Other Parties Representing:                                Begin Date:
                Claimant:                                                  End Date:
                Claim Number:                                            Date of Prior ATLP:
                Date of Loss:                                            Next ATLP Review Date:
                Venue:                                                   Legal Expense Paid to Date:
                Projected Trial Date:                                    Current Budget Total:
                                                                         Projected Total Legal Cost:

I.    Executive Summary

II.   Detailed Case Summary

             A. Summary of Facts

             B. Procedural Posture of Case:

             C. Venue, Jurisdictional Considerations, Judge, Probably Jury

             D. Name and evaluation of plaintiff’s and other counsel

             E. Critical Issues and Experts

                1.   Critical Liability Issues
                2.   Expected Liability Experts
                3.   Critical Damages Issues
                4.   Expected Damages Experts
                5.   Other Critical Issues

             F. Evaluation (only if specifically requested by the claims professional)

             G. Summary of discovery responses relevant to the Medicare Medicaid and SCHIP
             Extension Act of 2007 (MMSEA).

      III.   Resolution Strategy (only if specifically requested by the claims professional)




      Litigation Management Program 2010
      General Litigation Guidelines
      Attachment A
      Page 1 of 2
IV.    Case Management

V.     Anticipated Legal Services, Claims Activity and Budget


     Summary of Claims Activity




     Summary of Legal Services




     Timekeepers                             Roles                                Hours




                                             Budgets/Legal Expense
                                                                                 Total of   Cumulative
                                                                      Current
                                                                                  Prior      Totals of
                                                                      Budget
                                                                                Budget(s)   all Budgets
     Case Assessment, Development and Administration
     Pre-Trial Pleadings and Motions
     Discovery
     Trial Preparation and Trial
     Appeal
     Expenses
                                                             Totals

 A proposed budget for the legal services estimated above
                       has been created in Legal eXchange.
                       is attached hereto.




Litigation Management Program 2010
General Litigation Guidelines
Attachment A
Page 2 of 2

				
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