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ECONOMIC DAMAGES CHECKLIST PERSONAL INJURY

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ECONOMIC DAMAGES CHECKLIST PERSONAL INJURY

1. Official name of case as filed:

Person for whom loss is to be calculated:

2. Attorney’s name:

Firm name:

Address:

Attorney’s email address:

Attorney’s phone number:

Attorney’s fax number:

3. Attorney’s assistant for this case:

4. Type of case (Check One)

Personal Injury – State Court Medical Malpractice – State Court Personal Injury – Federal court

FELA LHWCA Jones Act

Other:

5. Date analysis needed:

6. Date of Trial:

7. Please provide the following information about the plaintiff:

a. Phone Number:

b. Date of Birth:

c. Date of Injury:

d. Social Security Number:

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8. Education (Please check the highest level of education completed by the plaintiff) Elementary School (0-8 years)

High School (9-12 years) High School Graduate GED

Some College, no degree # of units completed

Associate Degree Bachelors Degree Masters Degree

List any Advance Degrees received:

Other Education:

9. Plaintiff’s marital status: Single Married

Spouse’s name:

Spouse’s date of birth:

10. Plaintiff’s dependent children:

Name Date of Birth

11. Plaintiff’s annual earnings for five years prior to injury: (Please provide supporting documents.)

Year Earnings Employer Job Title

(indicate if promotion)

Do the earnings in the year of injury include any post-injury compensation? Yes No

If yes, how much?

12. Employment at date of injury:

a. Name of employer at date of injury:

Address:

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b. May we contact the employer? Yes No

c. Name the person to contact at employer:

d. Date of hire:

e. Date last worked:

f. Date of termination:

g. Job title at date of injury:

h. Rate of pay at time of injury:

(per year, per month, per week or per hour) i. Was plaintiff a union member? Yes No

(If yes, supply union contracts between date of injury and present.)

Name of union and local number:

Telephone number:

Location (City, State):

j. Were there future promotions available to the plaintiff? Yes No

Indicate job title, expected date of promotion and pay increase

k. Did plaintiff receive overtime pay? Yes No (Please provide supporting records.)

l. Did plaintiff receive bonus payments? Yes No (Please provide supporting records.)

Indicate amounts for each calendar year:

m. Did plaintiff receive paid vacation? Yes No

How many weeks per year?

n. Did the employer provide plaintiff with an automobile?

o. Did the plaintiff have medical coverage provided by the employer? Yes No (If yes, please provide information on the type of coverage and the cost.)

p. Has medical coverage provided to the plaintiff been discontinued? ? Yes No If yes, on what date did coverage end?

(Please supply COBRA letter.)

q. Was the plaintiff covered by a retirement plan? Yes No

(Provide booklet or documents regarding the employer contribution to the plan.) Did the plaintiff contribute to the plan? Yes No

If yes, what percentage or how much?

r. Did the plaintiff receive a lump sum distribution from the retirement plan? Yes No If yes, when? How much?

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Amount per month and date when payments commenced: t. Will the plaintiff receive a retirement income from the plan in the future? Yes No

If yes, when? How much?

u. If the employer provides any of the following benefits in addition to the retirement plan, please indicate the employer contribution to the plan. (Please provide supporting documents.)

Plan Employer Contribution

Profit Sharing Plan

Savings Plan (401k, 403b, etc.)

Stock Options

13. Is the plaintiff totally disabled from future employment? Yes No

14. If the plaintiff is not totally disabled, what assumption should be made regarding future

employment?

15. Will there be a vocational evaluation in this case? Yes No (Please provide a copy of the evaluation.)

Name of person preparing report:

Phone number of person preparing report:

16. Will there be a life care plan or care cost report in this case? Yes No (Please provide a copy of the evaluation.)

Name of person preparing report:

Phone number of person preparing report:

17. If the plaintiff has returned to work, provide the following information for all employment after the date of injury: (Please provide supporting documents.)

Year Earnings Employer Job Title

(indicate if promotion)

18. If plaintiff is currently employed, please provide the following:

a. Name of current employer:

Address:

Phone Number:

b. May we contact the employer ? Yes No

(5)

d. Date of hire:

e. Job Title:

f. Rate of pay:

(per year, per month, per week or per hour) g. Is the plaintiff a union member? Yes No

(Supply union contracts between date of injury and present.)

Name of union and local number:

Telephone number:

Location (City, State):

h. Are there future promotions available to the plaintiff? Yes No

Indicate job title, expected date of promotion and pay increase

i. Has the plaintiff received overtime pay? Yes No (Please supply supporting records)

j. Has the plaintiff received bonus payments? Yes No (Please supply supporting records)

Indicate amounts for each calendar year:

k. Does the plaintiff receive paid vacation? ? Yes No

How many weeks per year?

l. Does the employer provide plaintiff with an automobile?

m. Does the plaintiff have medical coverage provided by the employer? Yes No If yes, please provide information on the type of coverage and the cost.

n. Is the plaintiff covered by a retirement plan? Yes No

(Provide booklet or documents regarding the employer contribution to the plan.) Does the plaintiff contribute to the plan? Yes No

If yes, what percentage or how much?

o. If the employer provides any of the following benefits in addition to the retirement plan, please indicate the employer contribution to the plan. (Please provide supporting documents.)

Plan Employer Contribution

Profit Sharing Plan

Savings Plan (401k, 403b, etc.)

References

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