The types of substantive litigation support services I can provide include, but of course are not limited to:
Review and organization of complex medical records
Upload the records “as is” via your preferred secure encryption service, or send me a CD or thumb drive. I can create searchable PDF bookmarked master files, organized chronologically, by provider, and/or for special purposes, that are bookmarked in detail, can be used as the master templates for physical notebooks if needed, and can be easily updated at any time. I can highlight and organize key medical records in the manner that is most helpful for the attorney, client, or expert review, paying close attention to evidentiary issues, whether it is key medical providers, surgical instrument counts, anesthesia administration, nursing encounters, imaging studies, lab values – or anything else that is critical to understand your case.
Prepare medical chronologies.
A medical summary can be simple or complex, highlighting key dates of service or evidentiary issues. A detailed chronology can be used to identify pre-existing issues, relevant facts, missing medical records, and related medical bills. Attorneys I have worked for in the past have relied on them for settlement presentations, depositions, pleadings, expert meetings, mediations, and trials. I highlight what is missing, and can also prepare a simple memo that can be used for discovery purposes, correspondence, or preparation of medical requests. I have prepared minute-by-minute summaries, cross-referencing all relevant documentary evidence and identifying all individuals involved in each period, not matter how minute, as well as summaries of just radiology reports, lab reports, or particular medical issues or kinds of service. I can also analyze EOB statements, medical bills, and pharmacy statements to make sure the medical chronology is accurate.
Write medical and/or factual narratives.
These narratives can be used for any purpose, including motions and pleadings, with or without page cites. I can Bates-stamp the PDF records for citation purposes if needed.
Prepare deposition and document summaries.
I can prepare short or long form summaries, memo or line by line, in whatever format the client requests. If time is tight, I can do “quickie depo” summaries focusing on narrow issues, such as expert witness history and standard of care opinions.
Review and summarize discovery responses
In addition to preparing memos summarizing all responses, including objections and non-responses, I can prepare PDF notebooks organizing discovery and document production for your quick reference.
Prepare detailed witness and background notebooks
I can perform detailed research and organize the results in bookmarked searchable PDF files that can also be used as the master template for physical notebooks if needed.
Perform medical research
I can also prepare bookmarked searchable PDF medical literature notebooks, including a bibliography, relevant guidelines or policies if applicable, and the most relevant and critical research that applies to the case, as well as memos with a summary of the research.
Prepare spreadsheets summarizing damages
Analysis and review of medical bills includes calculating all documented payments and possible liens (group insurance, Medicaid, Medicare, self-pay) and balances. These can be easily updated in cases with ongoing production of documents or medical treatment.