Best of Philadelphia: Accident Checklist

After an accident you will need to explore all of the different decisions that will have to be made during the litigation to assure success.  Here is a checklist that should help you.  Call me at 610 642 7676 if you need more help.  For more of my checklists, click here.



— Consider the type of lawsuit and location where it should be filed.

— Make sure you are still within the statue of limitations deadline.

— Research complaint drafting.

— Carefully prepare the lawsuit papers.

Before the Proceedings:

— File the suit with the court.

— Promptly and properly serve the suit papers on the defendants.

— Make contact with the defendant’s lawyer.

— Send interrogatories and request for production of documents to the defendant’s lawyer.

— Complete gathering any proof of losses and damages that you will need to prove your case.

— File a discovery motion if answers to interrogatories and response to request for production of documents are not received promptly. (See Appendix 7 of my book, Winning Your Personal Injury Claim.)

Once the Process has Begun:

— Take the defendant’s deposition.

— Prepare for your deposition.

— Return to your doctor if your symptoms persist.

— Document lost earning capacity by retaining a vocational expert and/or an economist.

— Obtain a disability statement if you are claiming lost earnings.

— Be sure your medical evidence has a statement causally linking the accident to your injuries.

— Be sure your medical evidence has a statement as to future surgeries and medical bills, if necessary.

— Prepare for any independent medical examinations.

— Respond promptly to any motions filed by the defendant’s attorney.

— Prepare for any settlement or pre-trial conferences that are scheduled.

— Schedule videotape depositions of any doctors or expert witnesses.

— Prepare carefully for those depositions.

— Prepare your testimony.

— Prepare cross-examination of the defendant and defendant’s fact witnesses.

— Subpoena your witness for trial.

— Prepare your witness for testimony.

— Prepare your opening and closing statements.

— Prepare your voir dire questions.

— Prepare your jury instructions.

— Prepare to cross-examine the defendant’s expert witnesses.

— Familiarize yourself with the state and local or federal rules of evidence.

— Familiarize yourself with state and local or federal rules of civil procedure.

— Familiarize yourself with the rules of appellate procedure.

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