Checklist of Items to Obtain for Files on Personal Injury Case

Checklist of Items to Obtain for FilesPersonal Injury Case The following items should be in your file, from the early investigation of the case, before you consider taking depositions or sending out interrogatories, or taking steps to complete the preparation: 1. A copy of the police report. 2. Detailed notes of the plaintiff's version of the accident. 3. Statements of all known witnesses including those listed on the police report. (Do not accept the statement obtained by the police as being complete; often more information can be obtained from the witness.) 4. A list of all known witnesses with their statements in the file, or if a statement has not been obtained, a reason as to why no written statement was obtained from that witness. 5. Photographs of the scene and of the cars. 6. Accurate maps of the scene, with accurate measurements of all material items. 7. Investigation report showing why certain witnesses have not been contacted, if such is the case. 8. Investigation report showing that all of the homes, businesses, and other places close to the scene of the accident have been canvassed for possible witnesses. 9. Notes of your visit to the scene showing important factors that you may have observed about the scene which may later become valuable. 10. Copies of all news reports of the accident (often photos can be obtained from the newspapers or TV stations). 11. Weather conditions for the time and place of the occurrence. 12. Records of the State Highway Department showing the markings on the highway and the traffic control devices in existence at the time of the accident. 13. Records of the Worker's Compensation Commission of all your client's previous injuries. 14. Veterans' Administration medical records of your client. 15. All hospital records (including nurses' notes) of your client's hospitalizations occurring before the accident. 16. All your client's hospital records (including nurses' notes) for hospitalizations occurring since the date of the accident. 17. Earnings statements from your client's employer. 18. Statements of witnesses concerning your client's injuries, containing the effect of the injuries on his work and social activities. 19. Repair bills or repair estimates to plaintiff's and defendant's cars. (It is important to see the mechanic early if possible to obtain from him a statement of exactly the manner of the damage to the vehicle while it is fresh in his mind. For the use of this information see infra § 3.02). 20. List of the previous owners, if any, of the vehicles involved in order to determine the condition of the vehicles at the time of the collision. 21. Inspection report of the last date of inspection of both vehicles in those states where inspections are required, and also when trucks, buses or taxis are involved. 22. Credit report on the defendant. (This could become necessary in the event of limited insurance coverage, and it also might show history of prior accidents.) 23. Criminal Identification Bureau report on both the plaintiff and the defendant (if obtainable). 24. Statement from the Department of Motor Vehicles as to the ownership of both vehicles involved. (Often the police report does not show the correct ownership of the vehicles as the parties may have been mistaken about the names in which the vehicles are titled.) 25. Up-to-date medical reports from plaintiff's doctors. 26. Tax returns for the plaintiff for the preceding five (5) years. 27. School records of grades and attendance of a plaintiff who may have been attending school at the time of the collision. 28. Copies of plaintiff's last physical examination made prior to the accident, either from his employer or from his personal physician. 29. Social Security record of plaintiff's prior earnings.