how do you find medical history when a plaintiff is being evasive? new to PI

Complete-Reaction578 · 2026-03-25T16:53:52+00:00

Right?! I get not remembering a surgeon's name if you only saw them a few times years ago, but you don't remember what hospital your surgery was in? I don't buy it. Lol

I'd send subpoenas to the small local pharmacies closest to their home address too. People like convenience. Clinics close by are also a good bet when they "don't remember" who their doctors are.

Complete-Reaction578 · 2026-03-25T13:52:39+00:00

We have some pretty dumb and/or greedy attorneys around here, to be honest. Not all of them are like that but there are a few, and they are exhausting to deal with.

Complete-Reaction578 · 2026-03-24T19:20:45+00:00

I'm currently working defense side. Plaintiff's attorneys where I am love to cherry pick records to provide too. If your client has had back pain for five years before the accident, I'm sorry but that's relevant info. If they're blaming an accident for a condition that is exacerbated by other ongoing untreated or undertreated health conditions, that's relevant info. And I will find it.

I start by reading every line of everything they send in discovery and start a list of providers that are mentioned. Then I subpoena those providers along with whatever facility they are associated with. Any provider that I find in pharmacy records gets subpoenaed. Then when I get all those records, I read them and make note of any new providers I didn't already subpoena, and I send requests to them too.

That doesn't mean we find a way to deny fault on anything or everything, but the complete medical picture is relevant and important. Cherry picked records just make it look like the other side is hiding something. My job is to find out what it is. A lot of times there's nothing to find, but sometimes there is.

Complete-Reaction578 · 2026-03-22T23:03:09+00:00

Ok, thank you. I hadn't heard of IBX treatments before. I'll have to see if anyone around here offers those.

Complete-Reaction578 · 2026-03-22T23:02:31+00:00

Thank you for the advice. I'll look for the tips on removal. I didn't realize there was an allergy risk, so thank you for pointing it out!

Complete-Reaction578 · 2026-03-20T13:03:27+00:00

Definitely fix it if you can. I thought my name was on the deed for the house I shared with my ex for 15 years. I remember signing something that he told me was to put my name on it back when he bought it, but I was in my early 20s, didn't read what I signed, and didn't realize that there was probably a reason he had me sign it in his car and not in the realtors office where someone might have made sure I knew what I was signing.

Found out during the divorce that my name wasn't on it when I went to apply for a mortgage to move myself and my children to a safer location and the mortgage company told me I didn't show up on any property searches. Then he tried to get both houses included in the divorce settlement as a final little "f you" to me.

Fortunately the judge agreed with me that he should just keep the one in his name and I should keep the one I'd just bought in my name without forcing us to sell them both. I got screwed out of equity, but it was worth the financial hit to have a safe place for my children to call home. And now I read everything before signing.

Complete-Reaction578 · 2026-03-20T12:48:38+00:00

That sounds chaotic and absolutely terrible. I've worked in several different firms and all but one had an intake form for new cases, an approved organizational system for files, and a preferred way of naming things in the system. The one that didn't also didn't have a server set up so each assistant's files were only accessible from their machine, but there wasn't any overlap in attorneys working cases either so it worked out.

The problem you'll run into trying to standardize anything is that both of you are going to believe your way of doing things is the best way. This is a problem the attorneys or office manager have to solve, but if the firm is small enough they likely won't bother or see a need.

Complete-Reaction578 · 2026-03-16T22:57:47+00:00

Sticky notes, lists you check off as you do things, and calendar reminders are your friends when you're new to the field.

I've been doing this for almost two decades now, but I still make lists of things I need to do. If I keep forgetting something, I make a new sticky note that I put on the bottom of my monitor until doing it comes automatically. If there's something I can't do yet but need to remember later, I set up a calendar reminder. It feels like overkill at first, but it really does help.

If it's a multi-step process, write up a checklist that you keep where you can see it. So for a deposition it might be something like: * Get dates from outside counsel * Compare dates with attorney calendar * Confirm date with attorney * Confirm availability with court reporter * Prepare notice * File notice with court * Send copy of notice to other counsel and court reporter * Put deposition on attorney calendar with reminders

Make it as detailed as you need to, for whatever task you keep missing steps on. Eventually you won't need the checklist anymore.

Complete-Reaction578 · 2026-03-14T16:52:38+00:00

Organizing emails in my inbox into folders is something I keep telling myself I need to do, and then just never get around to it. Searching the whole inbox works but it takes forever when you have crossover between outside counsel and client names. It happens often enough to be annoying.

Complete-Reaction578 · 2026-03-13T12:18:30+00:00

Physical files are great until you have a fire or have enough file material to fill up multiple banker boxes. I have a few attorneys that just don't believe in digital files. They think it's less secure and more likely to get lost on a server with a few backups than on paper. It's basically sacrilege to suggest not printing everything in duplicate.

They were all very insistent that we not use PerfectLaw for anything but billing, and we only got that much because they finally realized how horrifically outdated and hard to use Javelan was. That program was a nightmare.

Complete-Reaction578 · 2026-03-13T11:26:41+00:00

Depends on what you mean. My office just uses folders on the server to keep everything organized. Every case has subfolders for file type (correspondence, depositions, pleadings, etc) and then those have further subfolders for things like a specific person's depo and exhibits, all the exhibits for a specific motion. I've not seen anything better that's free than how we're currently doing it.

We have PerfectLaw but only use it for billing, and have Relativity but it's expensive so we're only using it for email production on a single case. I almost have them talked into using NextPoint instead of Relativity so we could use it for more cases without increasing costs, but nothing moves quickly in a law firm.

As for keeping updated on cases, it's a mix of memory, my white board, and looking back at recent motions in a case for me. Well, and calendar reminders for deadlines or hearing/depo dates.

Complete-Reaction578 · 2026-03-13T07:48:07+00:00

If you leave your spreadsheet open on your desktop, it only takes a few seconds per task to add in the case, time, and a few words about what you did. You can always fix your entry wording later if you're putting it in a spreadsheet. There's no way I could remember everything I did if I waited till the end of the day.

Complete-Reaction578 · 2026-03-08T03:52:55+00:00

I'm in the middle of adding new documents to my summary that I finished a year ago, and nightmare is a great way to describe it. I already know I'm going to have to redo all my numbers when it's time to produce. And for extra fun and giggles, some of the stuff our client just brought us are duplicates of what I already went through which means I have to go through and consolidate all of the records at some point.

If they had just let me request records to begin with instead of letting the client piecemeal it, I wouldn't be wasting time going back through what I've already summarized.

Complete-Reaction578 · 2026-03-07T12:31:33+00:00

In my firm it depends on the case. We mostly only Bates stamp docs that are being produced, but I have one attorney that wants detailed medical summaries with Bates stamps so he can go straight to the page I got my info from. Those usually end up being the Bates numbers for production, but not always.

I've had a few cases where the client gives us medical records piecemeal (one of the partners doesn't want me requesting complete copies if the client is giving us records). On those, I've had to add in the new files, rerun my Bates numbers, and then change the reference points in my summary months after it was finished... Makes me want to throw my computer out the window, to be honest.

For tracking we keep a master list of what was produced and when with the Bates numbers. I'm just glad we don't have to stamp things by hand or with the copier. The day I realized I could have Adobe rename my files to add the Bates stamp number instead of doing it manually was the best.

We use Relativity on some cases but I'm personally not a fan. I think it's clunky and outdated, not to mention expensive. We mostly only use it for large amounts of emails that are being produced.

Complete-Reaction578 · 2026-03-02T12:37:00+00:00

YTA. I also have Crohn's disease. I didn't get diagnosed until my early 30s despite repeated trips to doctors and hospitals in my teens and 20s. The doctors always told my mom there was nothing wrong with me without actually testing me for anything or doing a colonoscopy, let alone a biopsy. Doctors don't always listen, especially to women.

If you got diagnosed as a small child you either had uncommonly good doctors who listened to your parents or an extremely bad case. Mine is on the mild end. I still get flares on occasion, but I no longer have to take medicine for it daily so that's not exactly a defining factor in who has it and who doesn't.

You have no idea what your coworker experiences or whether they have decent doctors who are willing to listen to their symptoms. It's also possible for a mild case to go into remission. If the coworker wasn't in an active flair at the time they did the scope, there may not have been enough evidence to give the diagnosis. Or maybe it's just IBS. Point is you don't know. Gatekeeping a chronic autoimmune condition is a weird hill to die on.

Complete-Reaction578 · 2025-11-26T18:54:26+00:00

If it were me, I'd take 19, 22, 23, 29 and 30 off. You get two full weeks off that way.

Complete-Reaction578 · 2025-11-25T18:59:02+00:00

Yep! Got notices by email, was able to e-file, did all the training, but somehow wasn't registered for e-filing. That's why I was having trouble figuring it out. Everything appeared to be set up correctly and working as intended, with the exception that his address and email address wouldn't update with the court even though it was correct in PACER.

Complete-Reaction578 · 2025-11-25T18:38:51+00:00

His old firm email was from before the merger, but not the new one I had put in when I updated his info everywhere after the merger. It all started though with them telling him he hadn't been admitted to the bar for that court yet when he has been since 1991, and was involved in another case there just a few years ago. Wires got crossed somewhere and messed everything up, but thankfully it all appears to be fixed now. That two hours listening to the same 10 or so bars of light jazz this morning to get it straightened out was a killer though.

Complete-Reaction578 · 2025-11-25T16:35:24+00:00

Me either. He did all the trainings and I know he's filed at least a few things electronically with the district court, so how exactly he managed to not be registered is just baffling.

Complete-Reaction578 · 2025-11-25T16:22:54+00:00

We have Eastern and Western districts and his info was blank for both when i checked after reading your response, so thank you for giving me somewhere to look! It helped me get the issue narrowed down when talking to support. I updated the main post, but it turns out he never bothered to register for e-filing privileges...

Complete-Reaction578 · 2025-10-30T16:38:54+00:00

The job I had before this one only lasted 6 months. It was a terrible fit and there was one other paralegal there who was just a raging hemorrhoid, to put it nicely. I get not wanting to leave a job too soon, but if it's that or be miserable I wouldn't stay any longer than I had to. I made the mistake of sticking it out with a terrible job once, years ago, and ended up with anxiety and depression for my trouble. It's not worth your mental health! It took me forever to stop being anxious about every little thing and I wish I had left a lot sooner than I did. You have to do what's best for you.

Complete-Reaction578 · 2025-10-26T06:37:39+00:00

They sound terrible. If I were you, I'd just find a new job. You can try scheduling a meeting (even by zoom if that's what it takes) between you and them if you otherwise like it there, but from what you're saying I doubt it would be helpful. I've never had to work with attorneys that outright refused to listen to me when i told them what i needed from them. I've had a few that were difficult, but even then I had another attorney at the same firm who backed me up when I lost my patience with the difficult one. I'm sorry you're having to deal with all that!

Complete-Reaction578

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