- []
- []
- []
It is anticipated that the above-named individuals or representatives of the above-named facilities will testify with regard to the treatment provided to Plaintiff, both before and after the subject accident. It is expected they may also comment on the reasonableness and necessity of the treatment received and expenses incurred. Further, they may comment on any diagnosis or prognosis made with regard to Plaintiff’s conditions related to the accident.
- Any and all custodians of record or other witnesses who are needed to establish a foundation for exhibits listed to be used at the time of arbitration or trial.
- Without waiving any objections, any and all witnesses listed by Defendant in [his/her] disclosure statement and all supplements even if later withdrawn.
IV. ADDITIONAL PERSONS HAVING RELEVANT INFORMATION
At this time, Plaintiff is unaware of any additional persons believed to have relevant information. Should such persons come to Plaintiff’s attention through the course of further discovery, Plaintiff will promptly supplement this Disclosure Statement.
V. PERSONS WHO HAVE GIVEN STATEMENTS
At this time, Plaintiff is unaware of any persons who have given statements. Should such persons come to Plaintiff’s attention through the course of further discovery, Plaintiff will promptly supplement this Disclosure Statement.
VI. ANTICIPATED SUBJECT AREAS OF EXPERT TESTIMONY
Plaintiff anticipates obtaining testimony from treating and/or expert medical specialists concerning the Plaintiff’s injuries, an accident reconstructionist, biomechanical expert or any other expert to render an opinion regarding the proximate cause of the accident and the forces involved. Plaintiff further reserves the right to elicit expert opinions from the witnesses listed by Defendant and to retain an expert to rebut any opinions proffered by Defendant’s experts.
VII. COMPUTATION AND MEASURE OF DAMAGES
Medical Special Damages [attach billing statements]: $
Lost Wages [attach income/wage loss verification]: $
Future Medical Expenses [need expert opinion] $
Future Impairment to Earn Income [need expert opinion] $
VIII. EXHIBITS TO BE USED AT TRIAL
- Accident/Investigation Report.
- Post-accident photographs of Plaintiff’s vehicle.
- Post-accident photographs of Defendants’ vehicle.
- All medical records and itemized billing statements pertaining to Plaintiff incurred as a result of the subject accident.
- Plaintiff’s employment records, income tax returns, and W-2s for the past five (5) years [showing income/wage loss].
- Plaintiff reserves the right to create demonstrative aids for use at arbitration or trial and move into evidence any courtroom exhibits.
- Without waiving objection, any and all exhibits listed by Defendant in [his/her] Disclosure Statement and any supplements.
- Any and all responses to discovery that have been generated in this matter and any responses generated in the future, including, but not limited to, Answers to Interrogatories, Responses to Requests for Production of Documents, and Requests for Admissions, and all documents gained through authorization or subpoena.
- Without waiving objection, any and all deposition transcripts generated in this matter including any and all exhibits.
- Without waiving objection, any and all pleadings, discovery responses and other tangible documents produced, served, exchanged or filed in the course of this litigation.
- The report and curriculum vitae of any experts in this matter.
- Plaintiff reserves the right to supplement exhibits as more become available.
IX. ADDITIONAL DOCUMENTS
- At this time, Plaintiff is unaware of any additional documents. However, if additional documents are discovered between the date of this Disclosure Statement and the time of trial, Plaintiff will supplement [his/her] Disclosure Statement in a timely manner.
- [Defendant required to disclose the Declaration page for each applicable insurance policy that provided coverage to Defendant.]
X. RELEVANT INSURANCE INFORMATION
- [Not Applicable to Plaintiff]
- [Defendant is required to disclose the liability policy limits that were available and in force at the time of the subject accident.]
DATED this ____ day of _____________, _____.
Attorney for Plaintiff
ORIGINAL of the foregoing mailed this
____ day of ___________ 20__, to:
Attorney for Defendant
Arizona Personal Injury Complaints
Arizona Interpleader Actions
Arizona Discovery Documents
Arizona Pre-Litigation Documents
Disclaimer: The information and forms on this site are for illustrative purposes only. The information is not intended to be used by anyone other than a licensed Arizona attorney familiar with Arizona personal injury law. The forms and the information contained in them may not be up-to-date and must be independently reviewed, cite checked, rule checked, and otherwise verified by a licensed Arizona attorney. The information contained in the forms on this website cannot and must be relied on for the purposes of filing legal documents or otherwise pursuing a claim. If you have any questions about this, please contract and attorney at LamberGoodnow.com or by calling 602-833-1274.
Locations
Phoenix, Arizona
602-ARIZONA (602-497-4861)
2394 E Camelback Rd #600
Phoenix, AZ 85016
Denver, Colorado
303-800-8888
1700 Lincoln Street #2400
Denver, CO 80203
Chicago, Illinois
312-757-7777
141 West Jackson Boulevard #4219
Chicago, IL 60604
Tucson, Arizona
520-477-7777
1 S Church Ave #1000
Tucson, AZ 85710
Nogales, Arizona
520-394-4733
420 West Mariposa Road, Suite 200
Nogales, AZ 85621
Las Vegas, Nevada
702-625-7777
300 S. 4th Street #1400
Las Vegas, NV 89101
Reno, Nevada
775-386-6155
300 E. 2nd Street
Reno, NV 89501
Lamber Goodnow Injury Lawyers
© 2022 by Lamber Goodnow Injury LawyersTM. All rights reserved. A division of Fennemore.
M. Lamber is licensed in Arizona, Colorado, Illinois and New York only. G. Goodnow is licensed in Arizona, Colorado, Illinois, New York and Washington D.C. (inactive) only. Matters outside of these jurisdictions are handled by Fennemore Craig, P.C., lawyers licensed in the relevant jurisdiction or by or with the assistance of attorneys at other associated, co-counsel law firms who are licensed in the relevant jurisdiction.
* Chris Goodnow and Justin McKay, lawyers licensed in Arizona, are partners with and owner of the outside law firm of Goodnow McKay. He is not an employee or director of Fennemore Craig, P.C., or Lamber Goodnow, which is a division of Fennemore Craig, P.C. Instead, with written client consent, Goodnow McKay is a co-counsel law firm with which Lamber Goodnow associates on cases.
*IMPORTANT – READ CAREFULLY: Past results do not guarantee, warrant, or predict future case outcomes. Every case involves risk, including the risk of loss. Results turn on, among other things, the facts and law applicable to each unique case. You may have to pay the opposing party’s attorney fees and costs in the event of a loss. Lamber Goodnow Injury LawyersTM is a division of Fennemore Craig, P.C.
Read more here.
Disclaimer
Historic Success Rate and Results Not Predictive and Results Not Guaranteed
Past results, including verdicts and settlements, are not indicative or predictive of future results or outcomes. Every case is different, and case results turn on the unique facts, circumstances, and applicable law involved in a given matter. Every case involves risk, including the risk of loss.
Historic “success rate” (i.e., percentage of cases settled or won) is for informational purposes only. Past results and/or success rates are based on cases handled by personal injury group attorneys that have resulted in either (a) settlement (regardless of amount) or (b) trial/arbitration in favor of their clients. Matters in which either client or attorney terminated representation prior to the conclusion of the matter are excluded from this analysis. Under no circumstances can historical success rates, settlement rates, trial win rates, or any other historical data be used as an indication of what may happen in your case. The amount of a settlement is not a factor in this analysis or in the definition of “success.” Additionally, the amount of any healthcare provider liens and/or health insurance reimbursement/subrogation claims — and any reduction of these, if any, secured by the firm — is not included in the definition of “success.” You may have to pay the opposing party’s attorney fees and costs in the event of a loss.
We engaged an outside economic consulting firm to calculate our success rate. To learn more about the methodology used by the economic firm, you may read its full report by clicking here.
There are never any guarantees about case outcomes. It is possible that any case can end in a loss regardless of what has happened in other cases in the past.
Cases Handled by Different Lawyers, including Lawyers Licensed in Relevant Jurisdiction
Cases may not be handled by M. Lamber or G. Goodnow; instead, other lawyers within the firm may be assigned to handle the matter, or with client consent the firm may associate with attorneys at outside law firms to handle the matter.
Cases are managed and handled by attorneys in the relevant jurisdiction. Marc Howard Lamber (“Marc Lamber”) is licensed to practice law in Arizona, Colorado Illinois and New York only. Gordon J. Goodnow III is licensed to practice law in Arizona, Colorado, Illinois, New York, and the District of Columbia (inactive) only. Matters outside of these jurisdictions are handled by firm attorneys licensed in the relevant jurisdiction or by attorneys at associated law firms licensed in the relevant jurisdiction.
Contingent Fee and Costs
In personal injury cases, we operate on a contingent fee. This means that our fee is a percentage of any recovery we obtain for you, whether by settlement or verdict. Clients are not responsible for paying us fees or costs if we do not recover. This does not include any of the defending party’s fees or costs that a court/arbitrator may assess against a client (e.g., in the event a case is not successful).
In the event of recovery, all case-related costs and expenses will be advanced by the firm or firms handling the matter, but the client agrees that these costs will ultimately be paid from client’s share of the recovery. Client has no obligation to front these expenses or to pay out-of-pocket for these expenses during the pendency of the case. If there is a financial recovery, however, the client agrees that the firm or firms will be reimbursed for these expenses out of the recovery; if there is no financial recovery, our firm will write off the expenses and the client will not be charged for them. Examples of costs and expenses include but are not limited to amounts paid to third parties not employed by our firm, costs of medical records, private investigators, expert witness fees and costs, shipping charges, messenger costs related to the execution of this agreement, electronic research charges, and other expenses borne by the handling law firm(s). If a lawsuit is filed and the defending party prevails, a court may assess the defending parties’ attorneys’ fees and/or taxable costs against the client.
Association/Co-Counsel with Outside Firms May Take Place
We may associate or co-counsel on certain matters with lawyers not in our firm. When this occurs, there is generally no additional fee for involving another law firm or lawyer; more specifically, the contingent fee percentage generally remains the same (if not, this would be disclosed the client and require an addendum to the controlling attorney-client agreement). In this situation, the associating attorney may serve as lead counsel on the matter. In the event a matter is associated, fees will be shared between Fennemore Craig P.C. and the associated law firm in an amount disclosed to the client in the attorney-client agreement or by another writing. As required by controlling ethics rules, Fennemore Craig P.C. and the associating law firm will remain jointly responsible for the matter. Even when a matter is associated and the co-counsel firm is serving as lead counsel, clients may always contact Fennemore Craig P.C. to inquire about the status of their matter.
This Web Site is Not Legal Advice
The information contained in this web site has been prepared for informational purposes only and is not legal advice. It is provided only as general information which may or may not reflect the most current legal developments. This information is not provided in the course of, and receipt of it does not constitute, an attorney-client relationship, and it does not substitute for obtaining legal advice from an attorney licensed in your state. Legal advice should take into account the specific facts of your situation, and you should not draw any particular conclusions from the information presented here. You should seek professional legal counsel before acting upon any of the information contained in this web site. Before sending information to us, however, please speak with one of our lawyers and get authorization to send that information to us.
No Attorney-Client Relationship Created
No attorney-client relationship is created by viewing this site. While we would like to hear from you, we cannot represent you until we know that doing so will not create a conflict of interest. Accordingly, please do not send us any information about any matter that may involve you until you receive a written statement from us that we represent you (an “engagement letter”). Similarly, no attorney-client relationship is created if you send us email. The best way for you to initiate a possible representation is to call one of our lawyers. He/she will first take you through our conflict of interest procedure and see that you are put in touch with the lawyer best suited to handle your matter. When you receive an engagement letter from the lawyer, you will be our client, and we may exchange information freely.
Any information provided to us before we have conducted a check for conflicts of interest and before we have agreed to represent you, is not subject to the attorney-client privilege or otherwise confidential and accordingly may be used by us for any purpose.
The use of Internet email for confidential or sensitive information, however, is discouraged, and we request that you first discuss with us by telephone the nature of the information you plan to send by this medium.
State Laws and General Information on Site
This website contains information about general or common rules that apply in some states. This web site also contains information about verdicts or settlements in past cases. You cannot assume that the same rules apply, or that the same result would occur, in your state or any particular state.
Blogs, Podcasts, Multimedia Issues
The materials on this site are prepared by Fennemore Craig. This site is a purely public resource of general information that is intended, but not guaranteed, to be correct and complete. It is not intended to be a source of solicitation or legal advice. Postings are not solicitations or legal advice and are for informational purposes only. This information is not intended to create and receipt of it does not constitute an attorney-client relationship. The reader should not rely or act upon any information in this site without seeking professional legal counsel. If you wish for Fennemore Craig to consider representing you, please contact the firm directly.
The authors of this site are licensed in the States of Arizona, Nevada and Colorado. The authors provide and will provide links to other websites for lawyers and other law sources related to various topics, but the authors do not intend such links to be referrals for employment. Further, the authors cannot vouch for the truth or accuracy of those sites. The authors do not wish to represent anyone who viewed this site in a state where the site fails to comply with all laws and ethical rules of that state.
The authors grant permissions to readers to link to this site so long as this site is not misrepresented. The authors will remove any link to any site from this site upon request of the linked entity. This site is not sponsored or associated with any other site unless so identified.
Circular 230 Client Explanation
On June 21, 2005, final regulations commonly known as “Circular 230″ became effective. Circular 230 was issued by the United States Department of Treasury. It sets forth detailed rules that tax practitioners (including attorneys and accountants) must follow when providing written communications regarding certain Federal tax issues. A “Federal tax issue” is a question concerning the Federal tax treatment of an item of income, gain, loss, deduction or credit, the existence or absence of a taxable transfer of property (such as whether a transfer to another is subject to Federal gift tax) or the value of property for Federal tax purposes.
When it issued Circular 230, the Department of Treasury articulated its objective to “restore, promote and maintain the public’s confidence in those individuals and firms” that provide tax advice. The failure by a tax practitioner to comply with the requirements of Circular 230 may result in severe penalties, including public censure, monetary fines and/or suspension or disbarment from practicing before the IRS. One nationally prominent tax practitioner and author makes the following observation regarding Circular 230:
[The Regulations] are any attempt by the Service to balance concerns about overly aggressive advice provided by some practitioners who were involved in the promotion of abusive tax shelters on the one hand, and the potential imposition of burdensome requirements on the great majority of tax practitioners who never issued such opinions. In that light, the final Regulations can be viewed as a compromise, but one that leans more towards enforcement. Once again, the many will pay for the sins of a few.
Circular 230 applies to not only formal legal opinions but also any writing relating to any Federal tax matter, including e-mail communications. In particular, tax practitioners must now comply with a number of detailed requirements when providing a “Covered Opinion,” including the following:
(i) the practitioner must make reasonable efforts to identify and ascertain all relevant facts and may not base the opinion on any “unreasonable factual assumption”;
(ii) the practitioner must relate the applicable law – including “any potentially applicable judicial doctrine” – to the relevant facts;
(iii) with very limited exceptions, the opinion must consider all “significant” Federal tax issues and reach a conclusion as to the likelihood that the taxpayer will prevail on the merits on each such issue (or if a conclusion cannot be reached, the opinion must so state);
(iv) the practitioner must reach an “overall conclusion” as to the likelihood that the stated Federal tax treatment of the arrangement or transaction is the proper treatment and set forth the reasons for that conclusion; and
(v) if any one of a number of conditions apply to the opinion, the practitioner must “prominently disclose” those conditions.
There are several categories of “Covered Opinions” which are generally not applicable to the tax practice currently maintained by Fennemore Craig. However, the definition of a Covered Opinion is very broad and generally includes any written communication (including e-mail) that (i) addresses a Federal tax issue, (ii) reaches a conclusion favorable to the taxpayer at any confidence level, and (iii) is intended to be relied upon by the taxpayer to avoid penalties.
Unfortunately, this firm (and many other firms and individual tax practitioners) anticipate that Circular 230 will increase the cost of delivering to clients written materials discussing tax issues. In most day-to-day correspondence – especially e-mail communications – the costs of complying with the requirements imposed by Circular 230 are likely to be prohibitive relative to the benefit of the written tax advice.
Tax practitioners can provide certain types of written communication on tax issues without complying with the extensive requirements of Circular 230 if the written communication includes a statement that the advice given may not be relied upon by the taxpayer to avoid penalties. Consequently, after June 20, 2005, clients of Fennemore Craig will see certain “reliance disclaimers” in various communications from the firm, including e-mail messages. It is anticipated that most written communications from Fennemore Craig attorneys that address Federal tax issues will also include the “reliance disclaimer” unless there is an agreement between the firm and the applicable client as to the need for an opinion that satisfies the requirements of Circular 230.
It is our intention to endeavor to continue providing the highest quality legal services to our clients in a cost-effective manner. Please call us if you have any question about how Circular 230 may affect our representation of you in connection with Federal tax matters.
Copyright Notice
©2016 Fennemore Craig, P.C. Fennemore Craig is the owner of the copyright in this web site. You may not copy, download, store, transmit, or otherwise make electronic or paper copies of this site, or any portion thereof, without express permission of Fennemore Craig. Permission is freely granted for most requests. All other rights reserved.
For questions email: info@lambergoodnow.com
“Lamber Goodnow” is a Division of Fennemore Craig, P.C.
The “Lamber Goodnow Injury Law Team at Fennemore Craig, P.C.” consists of attorneys, including M. Lamber and G. Goodnow, who are directors and/or employees of Fennemore Craig, P.C.; there is no separate “Lamber Goodnow” law firm or business entity.
“AV” and “BV” are Certified Marks of Reed Elsevier
AV Preeminent and BV Distinguished are certification marks of Reed Elsevier Properties Inc., used in accordance with the Martindale-Hubbell certification procedures, standards and policies. Martindale-Hubbell is the facilitator of a peer review rating process. Ratings reflect the confidential opinions of members of the bar and the judiciary. Martindale-Hubbell ratings fall into two categories: legal ability and general ethical standards.
