25 Things Lawyers Need to Know in Representing
Personal Injury Clients in Maryland
By Laura G. Zois
I have represented defendant driver(s), injured plaintiffs and insurance companies in auto accident cases in Maryland. From 1995 to 2002, I had the experience of defending auto insurance companies such as Allstate, Nationwide, State Farm, The Hartford, MAIF, and Bankers Independent Insurance Company. For the past five years, I have represented personal injury clients making claims against those companies (and others). This article gives advice for lawyers handles all types of personal injury cases with a focus on smaller personal injury case. My law firm no longer handles smaller cases but the lessons I learned in the trenches with these cases still informs my practice today.
So, going back, what did I learn the first seven years that has been invaluable knowledge to me in the last 12? A lot. The same mistakes were being made over and over again; recognizing this aided my defense of the insurance companies and prevents me from making those mistakes as a Maryland personal injury attorney. The best way to increase the value of your case is to avoid these weaknesses to the largest extent possible. The cleaner a case is presented, the better the settlement offer or verdict. This article is not intended to be a hornbook on how to handle an auto tort case. It is my 'best practices' learned from trying personal injury cases for both sides.
Get your own pictures
Invest in a good digital camera to preserve photos of your client's vehicle, injuries and the scene of the accident. Obviously, the insurance companies seek photographic angles to minimize or eliminate property damage to the vehicles involved in an accident where the company has exposure. Take your pictures and choose your own angles. Never count on your client to take quality photographs and do not count on the adverse driver's insurance company to take photographs of total loss vehicles. The adverse insurance company will always have a beautiful 8X10 glossy of the pristine bumper, but will conveniently misplace the total loss photos.
If you rely on your clients to take photographs of their own injuries, you will probably end up with pictures that are not very flattering and do not capture the essence of the injury. We have inherited cases where we have not even used the photographs depicting the injury because the fuzzy Polaroid in bad lighting with the family dog in the background was not going to help our cause. Join us all in 2013, please!
In cases involving a liability dispute, chances are you are going to try that case. It is often helpful to have photos depicting the roadway for the judge or the jury to put the scene in perspective. Oftentimes, parties cannot even agree on the layout of the road at the time of the accident. Roads change all the time, intersections change, and traffic signals controlling the intersection change. It is helpful to have accurate photos that depict the area where the accident took place. If your case may involve a liability dispute, get good photos of the scene before it changes.
Also, make sure you know exactly who your client is. Research their prior claims with an AISG report and check Maryland court records to see what your client's history has been.
- Get more information on settling up a claim the right way
Contact Witnesses Early
Memories fade, and the sooner you know exactly where you are, the more prepared you will be. In bigger cases, it is also helpful to get a private investigator PI to take recorded statements of the witnesses so you can refresh their recollection of events down the road. Additionally, when you represent the injured party that was not at fault for the accident, random bystanders tend to be more cooperative and sympathetic to your client as opposed to the negligent driver. Police officers often will not provide complete contact information for witnesses. If you contact them while the ink is still fresh on the police report, you should get additional contact information for them like their work numbers, dates of birth, and driver's license numbers, so when the trial comes, you will be able to track them down at their new address.
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Locate Health Care Providers 'Under the Radar'
How do you get your auto clients in for physical therapy? First, that is the wrong way to frame the question. First, see if they can find their own doctor. That is hard sometimes because injured clients often need someone who will not require payment up front. So this forces many to refer their clients to a doctor who regularly handles accident cases. It is not the first choice in most cases. But if you live in the real world, it sometimes is the best play for your client.
In smaller personal injury cases when the client needs an attorney's help in finding a health care provider, there is no question that Multi-Specialty, St. Paul and Biddle, At Last and their brethren will always have a place in the personal injury system in Maryland. They are experienced in treating injured patients, provide quality care, and have systems in place that make our jobs as personal injury lawyers easier (providing medical records in a timely and painless fashion for example). Furthermore, they will provide medical treatment for a client that has no PIP, health insurance, or means to pay for necessary medical treatment prior to the resolution of the case. The downside is that the health care providers that have lawyer-referred patients are vulnerable on cross-examination. As a defense attorney, I knew when I had the opportunity to cross one of these doctors it would dramatically affect the overall outcome of the case, even if the care and treatment to the patient were reasonable and appropriate.
The best advice - get to know the physical therapist down the street from your office, the general practitioners in your building, and the chiropractor on the corner. These practitioners that are not the usual suspects may have more credibility with the cynical adjuster or district court judge who sees the same health care providers over and over again. Furthermore, the local practitioners are also a good referral source for new clients.
Also keep in mind who this advice is really for: clients who have no other means of health care. If your client has a doctor they see regularly, that is usually the best path to take.
The Emergency Room Visit
Two of the first questions an adjuster, judge or jury will want answered are: (1) "How soon after the accident did you client seek medical treatment?" and (2) "Did the client go to the ER?" If you get a call from a potential client very shortly after an accident, make sure you impress upon him the importance of getting checked out right away. I explain to my potential clients that I am not a doctor, and I am unable to diagnose why he or she is feeling pain following an accident. It is in your client's best interest to be examined as soon as possible following any accident. I know some attorneys are uncomfortable recommending that their clients visit the ER for many reasons. Fear of this referral becoming an issue in front of a jury is outweighed by the real need for people in pain to be examined by a doctor. Adjusters, judges and juries rarely think a visit to the emergency room is unreasonable.
One pitfall to watch out for: Make sure you tell your client that they should not tell the ER staff that the reason they are in the emergency room is because his or her lawyer told them to go, otherwise, you could see an embarrassing notation in the records. (Of course, if this happens, you probably have an awful case anyway.)
Recommend a Visit to a Prior Health Care Provider
Typically, if your personal injury client does go to the ER, he or she will be discharged and advised to follow-up with his or her family physician. Again, if your client has a doctor, this is usually a good idea. Adjusters, jurors and judges almost invariably believe a person's injuries are more credible if the person goes to the family doctor he or she has trusted for years, in contrast to the client who only gets treatment from the doctor recommended by an attorney. Additionally, if you have a client that has a doctor that treated him/her for a prior injury or preexisting condition, have the client go back to that doctor.
This is important for several reasons. First, the prior doctor will know the patient's baseline and is in the best position to articulate and evaluate what exacerbations have occurred from the subsequent accident (if there is a potential preexisting injury issue). Second, it takes away effective cross-examination from the defense attorney as to why he or she did not go back to the trusted doctor whose surgery was so successful that he or she was back to 100% before the accident. Third, you are not in a position to lose credibility with the adjuster, judge or jury as to why the client picked your doctor over the client's existing doctor.
Do Not Allow Your Client to Give a Recorded Statement
Most adjusters will tell you that they need a recorded statement from your client to firm up liability or to assess credibility. Providing a recorded statement rarely results in a finding in your favor on liability, nor will the adjuster fall in love with your client over the phone and offer more money.
The only use for a recorded statement is for the defense attorney to take sound bites out of context and use them as cross-examination against your client at trial. Do not give the defense attorney any ammunition you do not need to give.
The obvious exception to this rule is an uninsured or underinsured case. Because these claims are breach of contract cases, the client's own insurance contract almost certainly contains language that make giving a full statement a condition precedent to recovery. Check to see when the claim was denied. If the claim was denied before the claim representative requests the statement, you may have grounds for denying his or her request and staying in compliance with the policy.
Please read the policy carefully. If it says it has the right to take the recorded statement to determine liability and it has already denied the claim, you may be able to deny its request. If you have to provide a recorded statement, discuss your client's statement with her before she gives it, and arrange for the client to come to your office to give the statement by conference call. Let the claim representative know you insist on a copy of the statement.
It is wise to remind your clients to write their Facebook, Twitter, Instagram, and so forth posts as if they will be read by the insurance companies. What can you clients post will actually help the value of their case? Absolutely nothing.
The Physical Therapist Is Not Your Buddy
Tell your personal injury clients that their physical therapists are not their friends, counsel or confidants. It is important that the client tell the health care provider everything necessary to provide proper care and treatment. So while his prior neck injury is relevant, the fact that it occurred during the three year stint he did at Jessup for assault and battery is not relevant to his care and treatment and, if mentioned, may find its way into the medical records. Providing details of their everyday life may damage your case if the impression is left that the client is really fine because she is going about her normal routine. "I had pain this weekend" is far superior to "I had pain this weekend in Ocean City." This accident victim may have been in pain and incapacitated the entire time she was on the trip but that will not be the message sent by that type of notation in the medical records.
While your personal injury client is in treatment, it is imperative for him to understand that if he has a subsequent injury, for better or worse, he must tell his treating doctors about the incident, and to let you know. Every adjuster will have access to a claims index. Auto accidents will appear on a claims index if the accident is reported by either party, even if there are no reported injuries. Subsequent accidents can create very effective cross-examination, even if there are no injuries, unless the patient tells the treating doctor about the accident and it is documented that the subsequent accident did not cause any increased pain or exacerbate the pre-existing condition. If your client has a subsequent accident and is not injured but does not tell his doctors about it, this will create a gray area for the defense and it will be used against your client. Take the ammunition away and make sure your client understands the importance of telling his doctors that he was not injured. If your client is injured in a subsequent accident, then it is important for his health care providers to know this information so they may proceed appropriately.
Make Sure Your Client Can Appropriately Articulate Injuries
Occasionally, we have clients that may exaggerate the severity of their injuries. This problem usually presents itself when a Plaintiff, who has not been properly prepared for his deposition, begins to testify inconsistently with medical records. For example, upon discharge, the medical report may state that the Plaintiff is not having any problems with the activities of daily living. The client then goes on to testify that she has not been able to brush her own hair since the accident, cannot walk up stairs anymore, and has pain on a daily basis that is a pain level of "10," even though she has not seen a doctor for these injuries in three years. If your client is going to be deposed, make sure she reads her medical records before testifying to help refresh her recollection and make she understands the importance of being honest and consistent.
On the other hand, the client at the other extreme is equally problematic: the "John Wayne" client that fails to articulate all of his or her complaints to his health care providers. Nearly every insurance company out there has a Colossus-type software program that it utilizes to assist the claims adjuster in evaluating the claim. Each system essentially works the same way and takes into consideration a large variety of factors. Each subjective and objective complaint that appears in a medical record is given a score, and weight is assigned to the complaint. For example, neck pain gets a certain amount of points; however, neck pain with associated headaches and numbness and tingling will be given a higher score, which ultimately translates into a higher evaluation. Furthermore, some clients will have lacerations, cuts, scrapes and bruising, but will fail to mention any of this to the health care provider. If the complaint does not make its way into the medical report, it will not be considered by the adjuster, and is unlikely to be considered by a judge or jury.
Keeping Appointments and Attending the Discharge Evaluation
Underscore with your clients why it is important for their recovery and their case that they keep their appointments and receive a final discharge from their providers. No-shows are indicative of a client who is not seriously injured. When the records from the physical therapist are littered with notations regarding no shows, cancellations, arrived late or left early, it is ammunition for the defense attorney and adjuster.
Failure to receive an appropriate discharge does not provide any baseline to evaluate the potential long-term sequelae of the injury. With some justification, the insurance company will assume in this instance that the patient has made a full recovery as of the last day of the medical treatment. Again, if it is not written down in the medical records, it does not exist to the defense attorney or the adjuster.
Verify Plaintiff's Prior Medical History
At every intake with a new client, it is important to spend time going over his prior medical history and past claims history. On countless occasions as a defense attorney, I was able to uncover prior medical histories and claims that the personal injury attorney was unaware of. There is no greater damning evidence than the existence of a prior medical condition or claim that was denied under oath by the Plaintiff.
Spend enough time with your clients discussing this issue at length. Explain to him in very direct terms that his prior medical history or claims history will be uncovered by any competent defense attorney or adjuster with access to a computer. In some circumstances, the clients may not remember whether or not they were injured on the job or made a claim for that car accident in which they were involved. You may want to consider sending a subpoena to the Workers Compensation Commission, your client's own insurance company, or index your own client through AISG.
Never Put in Writing to a Doctor That You Do Not Want the Jury to See
Do not send a letter to a doctor (or any expert or fact witness) that you would not feel comfortable seeing blown up larger than life, read aloud with feeling to the jury, and introduced into evidence at your trial. This also applies to e-mail and phone messages.
This is an innocent mistake many lawyers make. Defense attorneys will always subpoena a doctor's file, which usually includes all correspondence. Asking a doctor an opinion on causal connection is one thing, but telling the doctor what you need him to say is another. Another request by attorneys that I have seen in the past is a request to change a report. This is a bad idea even if a legitimate change is warranted. If you think there is a problem with the report, or your client points out a mistake, fixing the problem or correcting the mistake may cause more harm than good. The best way to avoid this pitfall is to simply pick up the phone and call the doctor to have a discussion about whatever the concern may be and have her prepared to resolve it at trial.
Do Not Sign a Medical Authorization or Agree to an IME Before Filing Suit
Adjusters will "try and make your job easier" by collecting the medical records for you. This is a bad idea. If you sign a blanket medical authorization, the claim rep will get copies of medical records that may not help you. The family doctor's records that reveal your client had a headache and body aches five years ago when he had a fever of 104 will be construed as a pre-existing condition of headaches. Similarly, your client's visit to the ER after a softball injury and the x-rays showing degenerative changes will be used against you.
Another trick used by the adjusters is, "I see that your client had a prior neck and back claim. If you get me his prior records that show he was discharged with no complaints, we can get this case resolved." Falling for this artifice does not help you or your client. Providing past accident records voluntarily only cuts down on the defense attorney's work when you file suit. The prior medical records will only provide the adjuster with ways to chip away at the value of your case. Really, there is no harm in doing it in a Circuit Court case - they get the records in discovery - but if I think you are better off 80% of the time just filing suit because giving them the priors rarely leads to a different settlement calculation.
In bigger cases with claims for permanency that are obvious early on, the adjuster may request an "IME." Think back to how many times you have actually gotten a favorable DME from the doctor cherry-picked by the insurance company defending - and declining - the claim. Voluntary submission to a DME will only cut down on the defense attorney's work, give the adjuster leverage, and possibly subject your client to another DME by a different doctor after suit is filed.
If Settlement Negotiations Fail Substitute
Sometimes settlement negotiations fail with adjusters and defense lawyers because of bad personal chemistry. It is not the settlement amount that is the problem; it is the lawyer who is demanding the settlement amount. Some adjusters would rather let a deal fall apart than give a particular lawyer a "victory" over him or her. In this case, bring in the "good cop" (or at least a different cop). The new cop comes back without all the built up animosity and while perhaps even admitting that the bad cop can be a little difficult at times, but agrees that the Plaintiff's numbers are in the right ballpark because of "X, Y, and Z".
This technique works well for us, but lawyers typically will not employ it because it requires taking yourself, or your partner, out of the deal. If you can set your egos aside, it is a great way to keep settlement negotiations alive on your terms. This practice works well in our office since we have the gender diversity mix, and occasionally certain claims representatives or defense attorneys prefer to deal with one over the other.
Know Your Adjusters
If you do enough auto tort litigation, you will come across the same insurance adjusters over and over again. Getting to know the people you deal with is a more enjoyable way to live and creates a relationship with people who are often enjoyable to work with, even in the ad versa rial process.
Tips on Each Insurance Company
It is critical to know which insurance company you are facing. Each one is different. We break down every auto insurance company doing business in Maryland here.
Adjusters typically fall into one of three categories, (1) "It is not my money, and I really want this file off my desk"; (2) "It is my money, all claimants are liars, I love to talk shop all day long, and I will develop an attitude problem if you disagree with me over this case"; and (3) My job is important, I am competent, and I evaluate cases fairly on a case by case basis. Luckily, most adjusters fall into category one or three. If you have an adjuster that falls into category number two, practice your patience and people skills, or see tip # 16 above.
Keep in mind when dealing with adjusters that they keep tabs on you. One attorney who now refers his cases to us told me that every final offer seemed consistent with the others; they seemed to know about where his settle point was. Some of the bigger insurance companies do have "files" on particular firms and attorneys. They know who is willing to try a case and who will accept a two times specials offer every time. They know who will wait until the pretrial to take their last offer and who will wait to settle the case on the courthouse steps. The claim reps talk just like we do, they know who the blowhards are and who the softies are. Make sure that the reputation you develop is one that maximizes the offers your clients get.
Do Not Send Out Medical Records as They Come In
Insurance adjusters will always ask in the initial contact letter for you to send them medical records as you receive them. As a general rule, our personal injury lawyers do not send out medical records until the medical package is complete. (This does not apply to PIP.) We do this for two reasons. First, it creates an administrative nightmare to figure out what has been sent and what has not been sent. If you send them out piecemeal, the adjuster may misplace some of the medical records and will need them all over again in the end anyway.
Second, if you have an accident case that involves a serious injury, an aggressive claim rep may start building a case against your client early on by obtaining surveillance early on. In a high stakes case, the claim rep will not hesitate to hire an investigator to dig up dirt on your client. This happened in a case where the claimant was telling her physical therapist she was not able to do her laundry or clean her own house. At the same time, a videotape was rolling while she was doing laundry as a housekeeper for another family. (Her explanation at trial was that she only said she could not do her own laundry or clean her own house !)
Prior Injuries and Conditions
Degenerative conditions and pre-existing problems will not necessarily cause your case to flounder. Claims representatives and defense attorneys invariably hang their hat on degenerative conditions (which we all have on some level) and pre-existing problems. Thankfully, we have the susceptibility instruction (MPJI 10:3) and aggravation of pre-existing condition instruction (MPJI 10:4). If you have either one of these issues, be able to articulate the difference between your client's problems and his treatment before the accident and his current condition.
Do not let a claims representative reduce the value of your case because of either of these two issues. The law is on our side; we just have persuade the suspicious and skeptical jurors and guide them toward following the law.
Demand Packages: Neat, Complete and to the Point
When preparing a demand package, make sure that it is done right. Too many personal injury lawyers in Maryland send out sloppy demand packages with missing medical records, missing bills, duplicate copies of junk, records that should not be in the demand package, calculation errors, and long-winded explanations about why the client deserves $500,000 on a case with $2,500 in medical bills.
Before any demand packages go out of our office, we make sure the medical records are complete, the records are reviewed, and the bills and lost wages are documented. The neater the presentation, the more confidence the adjuster will have in the attorney. I have known adjusters who will brag about taking advantage of a plaintiff's attorney's math errors.
Furthermore, the demand letter itself is not the personal injury attorney's opportunity to discuss ad nauseam what a fantastic witness your client will make and how she could not go to the first two weeks of cheerleading camp this summer, or how your avid golfer client has not been back on the links. First, it is a waste of time. Chances are you will have conversations with your adjuster about the facts of the case where you can articulate any points you need to make. Chances are the adjuster's authority will not change or hinge upon anything you have added to your demand letter in addition to what is in the medical records (Colossus does not have an entry for this). Second, you may inadvertently provide the adjuster or defense attorney with information that can be used against your client.
When making a demand, you certainly do not want to bid against yourself. If you are unfamiliar with the insurance company, have a case that has unusual damages, or are sending a demand in a case that involves a trucking company, you may wait it out and see what the carrier's initial offer is before making a demand. However, if you are sending a demand to one of the regulars in Maryland make your demand reasonable. A pie in the sky demand (without some reasonable basis) will tell the claims representative that you do not really know the value of the case is and you may also set yourself up for a low ball offer. This type of negotiation technique is often exhausting and counterproductive.
Send Out Demand Package with Discovery
Most insurance adjusters have between 100 and 300 pending files at any given time. The response time on demand packages varies greatly between insurance companies and individual adjusters. As a general practice, in our demand package we send a prepared 10-104 in District Court cases, and requests for admissions with our Circuit Court cases. It takes a little extra time to prepare the pleadings but will get the attention of your adjuster. In our demand package we ask the adjuster to call us within 10 days of receiving the demand package. If we do not hear from the adjuster within 10 days, we will call to confirm that they have received it and ask how long they need to evaluate the case.
Don't Get Caught Up in 'Time Specials' Math
The idea that a case should be valued by some multiplier of a client's specials favors the insurance company when the plaintiff's personal injury attorney looks at raw data and is influenced by it, especially when accident attorneys do not do the things they need to do to win cases and maximize the settlement offer. It also provides statistics that work against all of us as Plaintiff's attorneys. There are too many attorneys who will never try a case and will simply take what they can get in settlements as opposed to trying the case and allowing a jury to award a fair amount. Do not let their settlements become a part of your math.
Know When, Where, and How to File Suit
As a rule, we file suit as soon as settlement negotiations fail. In some personal injury accident cases, the carrier will call you back after you have obtained service on the defendant and increase their offer now that your case is in suit. It is good to keep track of which insurance companies do increase offers post suit and which do not. In some cases, we file suit contemporaneously with sending our demand package for this very reason. You can get a sample demand letter here.
If you are on the MAJ Listserve, you know some jurisdictions are better than others. If you have options of where to file, make sure you pick the jurisdiction that is going to be the most plaintiff friendly. If you are not sure, there are a lot of opinions on the Listserv on these topics.
If you have a case in Maryland that is not worth more than $10,000, you should file your case in District Court and ask for $15,000 instead of $30,000. Otherwise, you will end up trying a District Court case in Circuit Court. If your case is on the cusp of value between $15,000 and $30,000, have a heart-to-heart with your client. Also, their expenses will increase and it will take longer to get a trial date. Also, know your insurance companies. If the company typically writes $30,000/$60,000 policies, it generally will not bump up a case to Circuit Court, and expose its insured to an even higher excess verdict.
Know your Insurance Company
Keep track of your settlement negotiations with individual insurance companies. If you keep copious notes, you will see patterns develop. In some cases, every adjuster has virtually the same approach to settlement, and increases in settlement offers are doled out according to some master plan. There are certain insurance companies that do not want to expose their insured to an excess verdict, and will make a reasonable settlement offer in a Maryland Circuit Court case in which the amount asked for exceeds the policy limits. Finally, as mentioned earlier, sometimes all you need to do is file suit to get someone's attention. After filing suit, call the defense attorney and/or adjuster and see if their stance has changed.
Depending on the insurance company and the insurance adjuster, chances are the adjuster did not offer "Full Authority" prior to you filing suit. Some adjuster will assume that you are merely threatening to file suit and that you will call and accept their last offer before actually filing suit. Also, sometimes an insurance adjuster and an crash attorney may not see eye-to-eye on a case, and may have a falling out during settlement negotiations, so the full authority was never offered. However, the authority is the authority. The defense attorney assigned to the case will have the entire claim file, including knowledge of what the full authority is. If, for no other reason, it is a good idea to call when defense counsel gets in the case to touch base, and if you were close to getting the matter resolved, they may be willing to tell you the actual authority or even get a little more on the file to get the case resolved after they have had a chance to evaluate the file for themselves. Finally, keep in mind that a final offer is not necessarily a final offer.
Be Prepared and Organized
This should go without saying, but too many times I've seen many personal injury attorneys in Maryland try a case by the seat of their pants, have no control over witnesses, have no command of the facts and fumble through exhibits and testimony. The point needed to make the list.
Before your client answers interrogatories, gives deposition testimony or takes the stand, spend quality time going over the importance of being honest and accurate. The credibility and believability of a plaintiff is called into question before he or she ever takes the stand due to the current perceptions of the litigation process and the natural healthy skepticism juries have always had.
Before your trial, read through the entire file, including the records that you think are just duplicates of what you already have. When a defense attorney subpoenas records from your client's health care providers, past employers and insurance companies, he or she is trying to dig up dirt. Read every page of what they get in response to those subpoenas; chances are they got more than you did when you sent your request .
Prepare your client for the hard questions. Know the defense lawyer's case and try to take the sting out of it. Address the weaknesses in your own case and provide explanations for them. Do not try and turn your bumper scratch into a crumple; embrace the scratch and go with it. Do not try and elicit testimony from your client about how hard the impact was when there is no property damage.
If you have a minor impact crash with a delay in treatment, an explanation may be "it did not look like much of an accident so she thought her pain would go away quickly and she tried to tough it out." When she did not get better after a whole week, she went for treatment.
Prepare a trial binder. Have all your exhibits, discovery, pleadings and medical records easily accessible and organized. Jurors watch everything, and notice whether or not you are organized and on top of your game.
On the day of trial, be sure to advise your client to be cordial to all parties but to be aware of their surroundings. An overheard conversation between your client and her husband can offend a juror. Likewise for visits to the courthouse cafeteria and rest rooms. You never know who may be listening.
There you have it, my professional Modus Operandi, boiled down into a list of 25 tips. I hope this article has given you some ideas on how to maximize and improve the settlement value of your case or increase the verdict for your clients.
I am happy
to answer any questions you may have concerning the article or
auto tort questions in general.
Laura G. Zois
Miller & Zois, LLC,
7310 Ritchie Highway, Suite 1001
Glen Burnie, Maryland 21061
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