Format for Initial Case Evaluation Plan Sample Clauses

Format for Initial Case Evaluation Plan. In addition to the caption and a brief overview of the case, the case evaluation should include the following:  Pleadings – Identify the court and filing date, all parties and their attorneys, and all causes of action/theories of liability.  Summary of Facts – Briefly describe, based on review of records, discussions with Risk Management, and witness interviews: o Any relevant history, including the status of any internal investigations; o Age, education, employment, and marital and family status of plaintiff(s); o Identity and background of all named defendants and/or potential District witnesses. If interviews have been conducted, summarize them here; o The incident that forms the subject of the lawsuit; o Information about the actual or potential co-defendants, including the identity of their counsel; o For personal injury matters, the current status of plaintiff(s) injury, information on prognosis and further treatment.  Liability – Provide an opinion on the potential liability, including causation.  Damages – Provide any known information on potential general and special damages.  Legal Issues – Describe affirmative defenses, immunities, cross-actions, etc., and procedural approach thereto.  Early Disposition Potential.  Settlement History (if any).  Plan and Timeline – Describe anticipated discovery and trial preparation, including an estimated timeline. If any out of the ordinary expenses such as motion practice, sub xxxx, expensive expert witness fees, travel outside of the local jurisdiction, etc., are anticipated, Defense Counsel should include an estimate of such fees and/or costs in the budget. To the extent possible, you should also include an estimate of the number of interviews and depositions to be conducted.  Experts and Consultants – Identify consultant and potential experts by name, expertise, or specialty/sub-specialty.  Motion Practice – Describe any motion practice you anticipate. If plans change, please provide a written update.
Sample 1
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