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Library of Georgia Personal Injury Law Forms with CD-ROM (Print and Online)

  • ID: 2126932
  • Book
  • Region: United States
  • 560 Pages
  • ALM Media, LLC
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As much as victims need advocates, advocates need tools.

When representing a plaintiff in a personal injury or wrongful death case in Georgia, lawyers can rely on Library of Georgia Personal Injury Forms from the library of Fried Rogers Goldberg LLC. Why not start with the letters, pleadings and other forms crafted by a firm that has recovered more than $200 million in settlements and verdicts for its clients?

Library of Georgia Personal Injury Forms contains nearly 250 practice-oriented forms and sample letters from the library of plaintiffs' personal injury boutique Fried Rogers Goldberg LLC. The anthology includes a CD-Rom linking to MS Word forms that can be customized for each firm and modified for each case.

Each of the 16 chapters is preceded by a summary clarifying when its editor, Michael L. Goldberg, uses a specific form or document. And a detailed checklist can be found at the end of every chapter.

Among the myriad topics: notification of representation, preserving evidence, investigation of liability, proving injuries and damages, complaints, discovery, motions, responses, depositions, trial and resolution of claims.

Editor Michael L. Goldberg, a frequent speaker at legal seminars, is also author of three editions of Understanding Vehicle Claims, a legal treatise on trucking law.
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CHAPTER 1--DEALING WITH POTENTIAL CLIENTS AND SIGNING UP THE CASE

1-001 New Client Information Sheet

1-002 Fee Agreement Contract

1-003 Letter to Client Enclosing Fee Agreement Contract

1-004 Medical Authorization to Be Signed by Client

1-005 Employment Records Authorization to Be Signed by Client

1-006 Letter to Client: Investigating Claim Before Deciding Whether to Take Case

1-007 Authorization to Transfer File From Previous Attorney

1-008 Letter to Previous Attorney Requesting Client's File

1-009 Letter to Client: Co-Counsel Agreement

1-010 Letter to Referring Attorney Memorializing Co-Counsel Agreement

1-011 Thank-You Letter to Attorney for Referral

1-012 Thank-You Letter to Non-Attorney for Referral

1-013 Rejection Letter: Personal Injury Case

1-014 Rejection Letter: Medical Malpractice Case

1-015 Conflict Waiver

1-016 Chapter 1 Checklist

CHAPTER 2-- NOTIFICATION OF REPRESENTATION AND PRESERVING EVIDENCE

2-001 Letter of Representation to Defendant Requesting Insurance Information

2-002 Affidavit for Requesting Policy Limits

2-003 Letter of Representation to Insurer Requesting Policy Limits.

2-004 Ante Litem Notice to City

2-005 Ante Litem Notice to County

2-006 Notice for State Tort Claims Act

2-007 General Spoliation Letter

2-008 Trucking Spoliation Letter

2-009 Law Enforcement Misconduct Spoliation Letter

2-010 Escalator/Elevator Spoliation Letter

2-011 Nursing Home Spoliation Letter

2-012 Spoliation Letter to Preserve Surveillance Tapes

2-013 Letter Placing UM Insurer on Notice of Claim

2-014 Letter Placing Clients Insurer on Notice of Medpay Claim

2-015 Chapter 2 Checklist

CHAPTER 3--INVESTIGATION OF LIABILITY

3-001 Letter to Insurer Requesting Clients Recorded Statement

3-002 Letter Requesting Accident Report from Police

3-003 Open Records Act Request to Police for Entire Investigative File

3-004 Open Records Act Request for 911 Tapes/CAD Report

3-005 Letter Requesting Certified Copy of Guilty Plea

3-006 Letter to GBI Requesting Autopsy Report

3-007 Letter to GBI Requesting Toxicology Reports

3-008 Freedom of Information Act Request to Federal Governmental Entity

3-009 Freedom of Information Act Request to Federal Motor Carrier Safety Administration

3-010 Open Records Act Request to MARTA for Elevator/Escalator Incident

3-011 Open Records Act Request to Department of Human Resources

3-012 Open Records Act Request to Animal Control

3-013 Open Records Act Request to Police for Criminal History of Property

3-014 Open Records Act Request to Internal Affairs/Police Department for Excessive Force

3-015 Open Records Act Request to Department of Labor

3-016 Chapter 3 Checklist

CHAPTER 4--PROVING YOUR CLIENTS INJURIES AND DAMAGES

4-001 Letter to Client Requesting Damages Information in Personal Injury Case

4-002 Letter to Client Requesting Damages Information in Wrongful Death Case

4-003 Letter to Client Requesting Status of Medical Treatment

4-004 Letter to Employer with Wage Loss Verification

4-005 Wage Loss Verification to Employer for Personal Injury Claim

4-006 Request for Tax Returns to Internal Revenue Service

4-007 IRS Form 4506 for Requesting Tax Returns

4-008 Request for Clients Personnel File from Employer

4-009 Request for Clients Medical Records

4-010 Request for Clients Pharmacy Records.

4-011 Request for Clients Medical Bills

4-012 Request for Death Certificate

4-013 Letter Following Up on Request for Medical Records or Bills

4-014 Letter Requesting Updated Medical Records

4-015 Request for Diagnostic Films

4-016 Medical Expense Summary

4-017 Letter Requesting Military Service Records

4-018 Military Service Records Form 180

4-019 Chapter 4 Checklist

CHAPTER 5--COMPLAINTS

5-001 Automobile Accident: Two Vehicles

5-002 Automobile Accident: Passenger

5-003 Automobile Accident: Pedestrian

5-004 Automobile Accident: Family Purpose Doctrine

5-005 Automobile Accident: John Doe

5-006 Wrongful Death Section of Complaint

5-007 Punitive Damages Section of Complaint

5-008 Employer Liability Section of Complaint

5-009 Trucking Accident

5-010 Premises Liability: Slip and Fall, Foreign Substance

5-011 Premises Liability: Slip and Fall, Static Defect

5-012 Premises Liability: Negligent Security

5-013 Escalator/Elevator Accident

5-014 Dog Bite

5-015 False Arrest by Premises Owner

5-016 Employee Assault on Premises

5-017 Excessive Force Police Misconduct.

5-018 Medical Malpractice: Physician

5-019 Medical Malpractice Affidavit

5-020 Medical Malpractice: Hospital

5-021 Assisted Living Center

5-022 Dram Shop Liability

5-023 Products Liability

5-024 Georgia DOT/State Tort Claims Act

5-025 Bad Faith/Negligent Failure to Settle

5-026 Chapter 5 Checklist

CHAPTER 6 --FILING AND SERVICE OF THE COMPLAINT

6-001 Summons

6-002 Letter to Clerk Enclosing Complaint and Service on Defendant

6-003 Letter to Clerk Enclosing Complaint and Returning Original for Service

6-004 Letter to Sheriff to Serve Complaint

6-005 Motion for Appointment of Private Process Server to Serve Complaint

6-006 Order Appointing Private Process Server

6-007 Affidavit of Service for Private Process Server

6-008 Letter to Private Process Server to Serve Complaint and Discovery

6-009 Letter to Secretary of State with Complaint by Non-Resident Motorist Statute Service

6-010 Affidavit of Compliance for Non-Resident Motorist Statute Service

6-011 Certified Letter to Defendant Under Non-Resident Motorist Statute

6-012 Acknowledgment of Service

6-013 Letter to Opposing Counsel Enclosing Acknowledgment of Service Form

6-014 Motion for Substituted Service of Process by Publication

6-015 Affidavit of Attorney Supporting Motion for Service by Publication

6-016 Order for Service by Publication

6-017 Certified Letter to Insurer Enclosing Copy of Complaint

6-018 Chapter 6 Checklist

CHAPTER 7--DISCOVERY: INTERROGATORIES, REQUEST FOR DOCUMENTS AND REQUEST FOR ADMISSIONS

7-001 Auto Accident

7-002 Auto Accident: Family Purpose

7-003 Trucking Collision

7-004 Premises Liability: Fall Case

7-005 Premises Liability: Negligent Security

7-006 Escalator/Elevator Accident

7-007 Dog Bite

7-008 False Arrest by Premises Owner

7-009 Employee Assault on Premises

7-010 Employer Liability

7-011 Excessive Force Police Misconduct

7-012 Medical Malpractice: Physician

7-013 Medical Malpractice: Hospital

7-014 Assisted Living Center

7-015 Dram Shop Liability

7-016 Products Liability

7-017 Georgia DOT/State Tort Claims Act

7-018 Bad Faith/Negligent Failure to Settle

7-019 Jurisdiction over the Defendant

7-020 Underinsured/Uninsured Motorist Insurer

7-021 Direct Action Against Truck Insurer

7-022 Liability of Employer for Employees Conduct

7-023 Liability of Defendant for Collision

7-024 Certificate of Service of Discovery

7-025 Chapter 7 Checklist

CHAPTER 8--ANSWERING DISCOVERY FROM THE DEFENDANT

8-001 Letter to Client Requesting Information for Discovery Responses

8-002 Letter to Opposing Counsel Confirming Extension Time to Respond to Discovery

8-003 Response to Interrogatories

8-004 Verification of Interrogatory Responses for Client Signature

8-005 Response to Request for Production of Documents

8-006 Response to Request for Admissions

8-007 Supplemental Discovery Responses

8-008 Chapter 8 Checklist

CHAPTER 9--COMPELLING RESPONSES TO DISCOVERY

9-001 Letter to Opposing Counsel Requesting Overdue Discovery Responses

9-002 Letter to Opposing Counsel Requesting Complete Discovery Responses

9-003 Good Faith Letter to Opposing Counsel Under Rule 6.4

9-004 Motion to Compel Discovery Responses

9-005 Brief in Support of Motion to Compel Discovery Responses

9-006 Motion to Strike Defendants Answer for Failing to Respond to Discovery

9-007 Brief in Support to Motion to Strike Defendants Answer for Failing to Respond to Discovery

9-008 Letter to Opposing Counsel Requesting Verification to Interrogatory Responses

9-009 Chapter 9 Checklist

CHAPTER 10--DEPOSITIONS

10-001 Letter to Client Confirming Deposition

10-002 Letter to Opposing Counsel Confirming Deposition

10-003 Notice of Deposition of Witness or Party for Discovery

10-004 Notice of Videotaped Deposition

10-005 Letter to Doctor Confirming Deposition

10-006 Notice of Evidentiary Doctor Deposition

10-007 Notice of Expert Deposition for Discovery

10-008 Letter to Opposing Counsel Requesting Deposition of Corporate Representative

10-009 Notice of Corporate Representative Deposition for Discovery

10-010 Notice of Corporate Representative Deposition on Financial Issues

10-011 Letter to Witness Enclosing Subpoena for Deposition

10-012 Amended Deposition Notice

10-013 Chapter 10 Checklist

CHAPTER 11--OTHER DOCUMENTS RELATED TO DISCOVERY

11-001 Request for Production of Documents to Non-Party

11-002 Request for Cellphone Records

11-003 Letter Enclosing Subpoena for Driving Record

11-004 Joint Motion to Extend Discovery Period

11-005 Order Extending Discovery Period

11-006 Consent Scheduling Order

11-007 Consent Protective Order

11-008 Chapter 11 Checklist

CHAPTER 12--MOTIONS AND RESPONSES

12-001 Motion to Add Party Defendant

12-002 Brief in Support of Motion to Add Party Defendant

12-003 Motion for Default Judgment

12-004 Certificate of Default

12-005 Order Entering Default Judgment

12-006 Motion to Enforce Settlement

12-007 Consent Motion to Dismiss Less Than All Parties

12-008 Order Dismissing Less Than All Parties

12-009 Consent Motion for Continuance from Trial Calendar

12-010 Brief in Response to Defendants Motion for Summary Judgment

12-011 Response to Defendants Statement of Material Facts

12-012 Plaintiffs Statement of Material Facts to Which There Exists a Genuine Issue to Be Tried

12-013 Theory of Recovery

12-014 Affidavit of Witness

12-015 Notice of Filing Original Discovery

12-016 Request to File Original Discovery

12-017 Notice of Hearing

12-018 Stipulation Extending Time to Respond to Motion

12-019 Withdrawal of Motion

12-020 Chapter 12 Checklist

CHAPTER 13--LITIGATION LETTERS

13-001 Letter to Client Enclosing Medical Authorization for Defendant

13-002 Letter to Opposing Counsel Enclosing Medical Authorization Executed by Client

13-003 Letter to Opposing Counsel Requesting Records Obtained From Non-Parties

13-004 Letter to Client Explaining Independent Medical Examination

13-005 Letter to Expert to Review Records

13-006 Letter to Witness Requesting a Recorded Statement

13-007 Letter to Judge Enclosing Proposed Order

13-008 Chapter 13 Checklist

CHAPTER 14--TRIAL

14-001 Letter to Clerk Stipulating Case to Trial Calendar

14-002 Letter to Client Confirming Trial Date

14-003 Letter to Witness Enclosing Subpoena and Confirming Trial Date

14-004 Letter to Expert Confirming Trial Date

14-005 Consolidated Pre-Trial Order

14-006 Motions in Limine

14-007 Brief in Support of Motions in Limine

14-008 Letter to Opposing Counsel Enclosing Subpoena of Party

14-009 Order Allowing Video Equipment into Courtroom

14-010 Request to Charge

14-011 General Verdict Form

14-012 Chapter 14 Checklist

CHAPTER 15--SETTLEMENT AND RESOLUTION OF CLAIMS

15-001 Comprehensive Demand Letter

15-002 Unliquidated Damages Demand Introduction

15-003 Underinsured Motorist Coverage Demand Introduction

15-004 Policy Limits Demand Introduction

15-005 Request for Affidavit of No Additional Insurance Demand Introduction

15-006 Affidavit of No Additional Insurance

15-007 Offer of Settlement

15-008 Certificate of Service of Offer of Settlement

15-009 Consent Judgment

15-010 Assignment of Bad Faith Claim Against Insurer

15-011 Letter to Opposing Counsel Confirming Mediation

15-012 Letter to Client Explaining Mediation

15-013 Letter to Opposing Counsel Confirming Settlement

15-014 W-9 Tax Identification Form

15-015 Settlement Statement

15-016 Letter to Health Insurer About Possible Lien

15-017 Letter to Workers Compensation Carrier Denying Lien

15-018 Letter to Medicare Inquiring About Lien

15-019 Medicare Proof of Representation Form

15-020 Letter to Medicaid Inquiring About Lien

15-021 Letter to Lienholder Enclosing Compromised Payment of Lien

15-022 Letter to Referring Attorney Enclosing Fee

15-023 Chapter 15 Checklist

CHAPTER 16--ADMINISTRATIVE FORMS

16-001 Change of Address

16-002 Leave of Absence

16-003 Conflict Letter

16-004 Letter to Client Asserting Attorney Lien

16-005 Notice to Defendant/Insurer of Attorney Lien

16-006 Letter to Client Providing Notice of Withdrawal

16-007 Notice of Withdrawal

16-008 Motion to Withdraw as Counsel

16-009 Order Granting Motion to Withdraw as Counsel

16-010 Notice of Appearance of Counsel

16-011 Substitution of Counsel

16-012 Chapter 16 Checklist
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Michael L. Goldberg
Michael L. Goldberg is a partner in the law firm of Fried Rogers Goldberg LLC, where he concentrates his practice on representing victims of catastrophic personal injury and wrongful death. During the past five years, he has been lead counsel in seven cases with trial verdicts in excess of $1 million, including a $16 million wrongful death verdict in state court in 2009 and a $10.1 million verdict in federal court in 2010. Michael is a frequent speaker at legal seminars; has published numerous law-related articles, including several State Bar of Georgia Journal articles; and is the author of three editions of Understanding Motor Carrier Claims, a legal treatise on trucking law. He enjoys working with other lawyers, and the majority of his cases come from referring attorneys who associate him in as lead counsel to prepare a case for trial. Michael can be reached at Michael@frg-law.com.

For almost 20 years, the attorneys at Fried Rogers Goldberg LLC have represented personal injury and wrongful death plaintiffs in state and federal courts in Georgia and across the United States. The firm focuses its practice on handling trucking and commercial vehicle collisions and maintains a trucking law website at www.thetruckingattorneys.com. The firm also represents victims in the areas of vehicular accidents, premises liability, industrial accidents, medical malpractice, product liability and constitutional rights. The firms attorneys have recovered in excess of $200 million in settlements and verdicts for their clients.

Fried Rogers Goldberg LLC
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