At the heart of a personal injury claim are injuries. An attorney will inquire of his or her client if the client is experiencing pains, and, if so, how often they occur, how long they last, and whether the pains are mild, moderate or severe. The attorney will inquire as to whether the client has any visible signs of injury, such as a bruise, discoloration, cut, scar, swelling or lump. The attorney will request the name of each doctor, therapist and laboratory where the client has received treatment. The attorney will need to determine if the client has received examinations, tests or care in any hospital. The attorney will inquire whether the client has taken any medicine for his or her pain or injuries. The attorney will ask whether the client wears any brace, appliance, bandage, traction, crutches, wheel chair, special bed, mattress or board, medical collar, or other aids because of the client’s injuries. The attorney will request information regarding what home treatments the client has utilized, such as heat lamp, electric pad, hot water bottle, hot bath or shower, massage, special exercises. The attorney will ask whether there are activities at work, home or elsewhere that he or she could not do because of his or her injuries. The attorney will inquire as to whether there is anything at work, home or elsewhere that he or she finds more difficult to do because of his or her injuries. The attorney will request information on the client’s medical history and whether he or she has suffered any new injuries not related to the present accident. The attorney will ask whether the client lost any time from work because of his or her injuries.
[California Practice Guide: Personal Injury [certain citations omitted]]
