"Board Certified Civil Trial Lawyer"
February 2018
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Injury Diary

  1. INJURY DIARY WITNESSES – We would like for you to contact your friends and neighbors, persons at work, etc., and on a separate sheet of paper for each witness, give us their name, address and telephone number. Have them describe, or you describe in detail, on a separate sheet of paper what each witness knows about how this injury has changed your life. For example, your neighbor could tell about how you are not able to work as much around the house, or your friends could tell how you don't bowl now, or you don't do some other type of hobby. It is better if these witnesses are not your relatives. It is all right if they are your friends, because they would be more likely to have observed you. Again, please paint word pictures and give details and descriptions of specific instances. It is impossible to be too detailed.

  2. LOSS OF WAGES OR LOSS OF POTENTIAL INCOME-One of the major things in your case may be the loss of income or potential income. We wi11 need a copy of your union contract showing wage rates, copies of your W-2 forms, and your income tax returns for at least five years. Please obtain from your employer written documentation showing the exact days you missed from work because of this accident and the amount of money you would have made if you would have been working these days. If this injury has prevented you from being advanced in your employment or has prevented you from obtaining employment, please give us the names, addresses and telephone numbers of witnesses who may prove this for you. We would also like to know, in detail, what services you have been prevented from performing around the house, such as supervision of the children and all the other services performed either by a husband or a wife.

  3. KEEP A COPY OF YOUR ANSWERS – Please keep a copy of the answers that you give us in working up your material on INJURY DIARY because this will be helpful to you for the trial, depositions (your sworn statement), and for the answering of interrogatories (answers to questions).

  4. QUESTIONS OR HELP If you need help in writing your INJURY DIARY, please call this office for an appointment. Do not come in without an appointment.

  5. START MAKING NOTES The best way to with your INJURY DIARY is to just start, right now, making notes. Then, after a few weeks, prepare a copy for us and a copy for yourself. As time goes on, prepare additional information and send it in to the office.

  6. USE YOUR IMAGINATION — You know your own life better than we do. Use your imagination and go into all aspects of your life. Explain to us, in the greatest detail possible, how this occurrence has affected your life. Paint a word picture so that we can sell your most important product – YOU!