Format for Initial Case Evaluation Plan Sample Clauses

Format for Initial Case Evaluation Plan. In addition to the caption and a brief overview of the case, the case evaluation should include the following:  Pleadings – Identify the court and filing date, all parties and their attorneys, and all causes of action/theories of liability.  Summary of Facts – Briefly describe, based on review of records, discussions with Risk Management, and witness interviews: o Any relevant history, including the status of any internal investigations; o Age, education, employment, and marital and family status of plaintiff(s); o Identity and background of all named defendants and/or potential District witnesses. If interviews have been conducted, summarize them here; o The incident that forms the subject of the lawsuit; o Information about the actual or potential co-defendants, including the identity of their counsel; o For personal injury matters, the current status of plaintiff(s) injury, information on prognosis and further treatment.  Liability – Provide an opinion on the potential liability, including causation.  Damages – Provide any known information on potential general and special damages.  Legal Issues – Describe affirmative defenses, immunities, cross-actions, etc., and procedural approach thereto.  Early Disposition Potential.  Settlement History (if any).  Plan and Timeline – Describe anticipated discovery and trial preparation, including an estimated timeline. If any out of the ordinary expenses such as motion practice, sub ▇▇▇▇, expensive expert witness fees, travel outside of the local jurisdiction, etc., are anticipated, Defense Counsel should include an estimate of such fees and/or costs in the budget. To the extent possible, you should also include an estimate of the number of interviews and depositions to be conducted.  Experts and Consultants – Identify consultant and potential experts by name, expertise, or specialty/sub-specialty.  Motion Practice – Describe any motion practice you anticipate. If plans change, please provide a written update.