Maryland Injury Lawyer Blog

Our lawyers have long believed that professional expert witnesses’ financial information, including their tax returns, may be discoverable and admissible for the purpose of showing potential bias. Yesterday, the Alaska Supreme Court joined the list of jurisdictions that agree with us.

Noffke v. Perez is a car accident case wherein a wife and husband were awarded $54,000 and $24,000, respectively, by an Anchorage, Alaska jury. On appeal to the Alaska Supreme Court, the defendant claimed that it was error for the trial judge to require her expert witness to produce income tax records. Reading between the lines, it seems that after a motion to compel the records was sought and granted, the defendant’s expert did what many hired medical experts do after an order to produce their records: they refuse to testify.

The Alaska Supreme Court found that there might be a “plausible argument that the witness generates such a significant portion of his or her income from a particular side or particularly attorney that the expert’s impartiality can reasonably be questioned” making this information discoverable and admissible (emphasis added with joy).

The problem I have is that there are a number of doctors who are “Med Mutual doctors” or “State Farm doctors,” the folks that these insurance companies turn to when they need a doctor who is willing to go out on a limb to take a tough position. I do not believe I am being a cynic. This is just reality. To be willing to take this quantum leap from objective doctor to advocate doctor, these experts usually want to be well compensated. To be fair, this happens to some plaintiffs’ experts too, but I think this happens to a lesser extent. If for no other reason than the insurance companies have more of a market share than individual plaintiffs’ lawyers, increasing their leverage over experts. Our law firm has never called an expert to testify at trial who was personally financially beholden to us – insurance companies do it all of the time. (If I'm wrong about this, defense lawyers should join hands with me on this issue.)

Accordingly, it is fair game to question how much money they have made from (1) legal related work generally, (2) from a specific lawyer, law firm or company, and (3) how much money the expert makes overall. Why does the expert’s total income matter? Because without that information, it is easy for an expert to claim that, while he might make $200,000 a year doing legal work, it is a small portion of his income. To put that in fair context, the jury should know just what that portion is.

Unfortunately for these plaintiffs and their personal injury lawyer, Alaska Association of Trial Lawyer President, Michaela Kelly Canterbury, this case was reversed, but on other grounds (excluding certain medical exhibits and failure to give a comparative negligence instruction).

You can find the Alaska Supreme Court decision here.

The biggest intangible dealt with by personal injury lawyers in settling or trying a personal injury case is noneconomic pain and suffering damages. These damages defy ready conceptualization and the law provides little in the way of assistance to jurors who make the final call in the end.

In many of our personal injury cases we have used per diem reasoning to juries to articulate pain and suffering damages. Per diem arguments give some tangible basis for a pain and suffering award. In psychobabblespeak, per diem arguments are a form of anchoring -- the cognitive phenomenon of the tendency of people to make estimates with a value in mind. After an anchor is established, there is a bias toward that value to the exclusion of other evidence.

Critics of per diem or other mathematical formulas contend that it manipulates jurors, and is designed to implant in the jurors' minds specific figures and amounts, without a solid evidentiary foundation, to influence the jurors to adopt those figures and amounts in evaluating pain and suffering and measuring damages. This argument ignores the fact that there is never an evidentiary foundation for how to value pain and suffering. Moreover, how is it manipulating jurors to suggest a value pain by the hour or day when defense lawyers have full opportunity to argue why such a valuation is unreasonable? Some jurisdictions have bought into these arguments and have prohibited per diem arguments, which I think is completely unfair to victims who should be able to have their lawyers argue their pain and suffering any way the lawyer and the client deem fit.

Interestingly, some plaintiffs’ lawyers disagree with the efficacy of using per diem arguments. Some point to a study that found that only 23% of jurors said they would defer to the pain and suffering award suggested by the trial lawyers and only 40% would even consider the information in determining damages. But I also read somewhere that 92% of the people surveyed think campaign advertisements have no impact on the way they vote. In other words, I don’t think we can be believed when we are asked what influences us. Besides, if 40% of jurors are considering what you are saying, that is still a lot of jurors whom may not only be able to persuade other jurors, but may also be able to argue that position during the jury's deliberations.

In his book, Damages, David Ball suggests a related argument in closing that turns the tangible to intangible: “Total up the number of extra hours your client is forced to spend on the usual daily tasks of living such as dressing, eating, washing, toileting, getting to and from medical and therapy appointments, shopping for special need items, etc. If brushing his teeth used to take him three minutes but now requires six, and he brushes his teeth three times a day, that’s nine extra minutes a day just to brush his teeth. If that was eight weeks with a cast on his arm, that’s nine minutes times seven days times eight weeks, totally more than eight hours – just for brushing his teeth. If the injury is permanent and there’s a 35-year remaining life expectancy, the total is nearly 2000 hours.”

Under Ball’s paradigm, intangible, noneconomic damages are converted to tangible, economic damages by simply giving him his hourly wage for the total extra time he needs to spend, giving jurors larger economic anchor to use as the basis for their award. Ball also notes that this argument gives a personal injury lawyer a decent shot with “tort reform” minded jurors.

This is a great strategy in the right case. But, using David Ball’s words, pain is often the worst harm in the case. The per diem argument I think gives personal injury lawyers a chance to receive a favorable jury verdict for the pain their client endure.

There is another good blog post from the Drug and Device Law Blog this time regarding electronic discovery with respect to on-line diaries and the social networking like Facebook and MySpace. I have not had this issue arise with one of our clients but it is only a matter of time. Anything on there inconsistent with plaintiff's complaints is going to be used against them (as it should in most cases).

Speaking of which, you can find my Facebook profile here and my Linkedin profile here. If you are on Facebook or Linkedin, add me to your list of friends.

The case of Titan v. Advance was decided yesterday by the Maryland Court of Special Appeals. Titan is a case where the Plaintiff alleged negligent repair of a roof that led to the clogging of a roof drain, which then resulted in the flooding of the Plaintiff’s premises on Eastern Avenue in Baltimore, Maryland, at Crown Industrial Park. After a three day trial, the jury found in favor of the Defendants.

As you might have expected, the amount of rain after the job was completed was relevant. Defendants introduced, over objection, a certified copy of the U.S. Department of Commerce’s weather reports from Baltimore-Washington Airport, which reported rain patterns at the airport between the day roofing work was done and the date of the flooding off the roof. Plaintiff objected that the weather at Baltimore Washington Airport on that day was not relevant because it was 10 miles from the site.

The Maryland Court of Special Appeals, in an opinion by Judge Arrie W. Davis, found that the documents were relevant because the parties disputed the amount of rainfall. The court further found that in spite of the length of the documents, the jury could reasonably interpret the recorded rainfall amounts and no expert opinion was needed to explain the documents. As to the 10 miles between Baltimore Washington Airport and the site of the property, the court concluded this went to the weight of the evidence as opposed to admissibility.

Interestingly, the Plaintiff filed a claim with its own insurance company, Hartford, who paid some, but not all, of Plaintiff’s damages claim. Specifically, it did not pay all of Plaintiff’s business interruption loss. Plaintiff originally sued Hartford who prevailed on the always raised, but rarely used, affirmative defense of accord and satisfaction. As a part of the settlement in which Hartford paid a nominal amount, Hartford released its subrogation claim in this case.

In another issue of interest to personal injury lawyers, the question of when the existence of insurance can be introduced was also at issue. In most accident and medical malpractice cases where the client is being sued individually, plaintiffs want to get into evidence that the defendant has insurance to cover the claim. In Maryland, under Maryland Rule 5-411, generally evidence of liability insurance is not admissible. In this case, Plaintiff was cross-examined about its dealings with Hartford. Apparently, one of the Plaintiff’s agents made assertions to Hartford inconsistent both with Plaintiff’s contentions at trial and statements the agent was now making. The court found that the plain language of Maryland Rule 411 makes clear that evidence of insurance is admissible when offered for another legitimate purpose.

Certainly, the trial court did not commit reversal error in admitting this evidence. Usually the court will make every effort to shield the insurance issue from the jury by encouraging a stipulation that the statements were made, but still not disclose to the jury that they were made to an insurance company. In this case, given the context of the quoted testimony, it would have been very difficult to mask from the jury that there was underlying property insurance.

This is a worthwhile case for Maryland personal injury lawyers to read, both on the issue of admissibility of insurance, and with respect to the admission of weather reports, although the case does not break any new ground. You can find the Titan v. Advance here.

Last month, retired Howard County Judge Dennis M. Sweeney wrote an article in a series of articles he is writing for the Daily Record. The latest article discusses voir dire. One point Judge Sweeney makes is that judges have an aversion to proposed voir dire questions that seem to be uniform in every case the lawyer tries. In my last trial, the defense lawyer did not change the names of the parties from the voir dire that had apparently been cut and pasted from the last case. Judge Sweeney writes that they may poison the trial judge to ignore specific voir dire questions – usually put at the end of voir dire consistent with cut and paste practices – that may have more merit.

The article also points to dicta in Landon v. Zorn, 389 Md. 206 (2005), a failure-to- diagnose medical malpractice case in which the Plaintiffs appealed a defense verdict. The basis for the appeal was the trial judge’s refusal to ask whether the jury panel had any “preconceived opinion or bias or prejudice in favor of, or against Plaintiffs in personal injury cases in general and medical malpractice cases in particular?” The Maryland Court of Appeals affirmed in a unanimous opinion written by Judge Clayton Greene, Jr. that it is the responsibility of the attorneys to “propound voir dire questions designed to elicit potential bias from jurors, and not to bootstrap a tort reform argument on appeal to a general question inquiring into any potential ‘bias or prejudice’ against plaintiffs in personal injury or medical malpractice cases.” But as Judge Sweeney notes, the court did indicate that the lower court may have had an obligation to include a question more tailored to the plaintiff in that particular case if requested by the attorneys. Judge Sweeney went on to say that this “places counsel in the position of having to ask the question in many different formulations to hit on the one that may be correct and specific enough.”

But Maryland trial judges love to rush through voir dire as it is so I shuttered to imagine giving multiple formulations to these judges. I wrote to Judge Sweeney and asked if he had any solution to the Landon v. Zorn problem of having to ask the question in many different formulations to find the most appropriate, noting my concern about how multiple formulations of the same question might risk annoying the court.Judge Sweeney offered this practical response:

“I agree with you that putting multiple formulations in the voir dire could be counter productive if the judge is not receptive. Perhaps, a better way to handle it is to have the alternate formulations ready to propose if the judge tells you he will not ask the first proposal. Sometimes making the question more focused or narrow will get a judge to ask a question on the subject even if the question asked is not your first preference. If you feel strongly that the issue is one of great importance in picking an unbiased jury, I would not simply let a denial go by without communicating that feeling to the judge and providing him or her with an alternative formulation. You can even invite the judge to fashion his/her own as long as it fairly covers the issue. Obviously you have to pick the case and the issue carefully.”

It sounds like this solution gives Maryland lawyers the best shot at getting the court to pick a helpful voir dire question while also providing a legitimate appellate issue if a legitimate question is refused.

I’ve never conducted voir dire in another jurisdiction but I observed voir dire in other states. The difference is amazing - as different as checkers and chess. Do you think we should have more extensive voir dire in Maryland? I asked Judge Sweeney that as well:

“My answer is that it depends. We pick juries quickly in Maryland and there is a benefit in that, but obviously we want fair juries. My experience has been that jurors are incredibly conscientious and work hard to reach a fair decision. I don't know that putting prospective jurors through a lot more questioning is going to improve juries. However there are cases where it would probably be better to have additional questioning on issues of potential bias. I would not want to abandon our very efficient system which I think is generally fair in the process. It is also important to remember that jurors are basically forced labor given the pay they receive which is next to nothing. We should not waste their time or invade their privacy more than we absolutely need to get a fair jury.”

I’ve always been in favor of more elaborate voir dire because I really believe there are a small minority of jurors that plaintiffs are never going to be able to get to no matter what the facts. To a lesser degree, I’m sure there are also some jurors that defendants do not have a fair shot to persuade. So I think a process of more open-ended questions would give lawyers an opportunity to flush out more dogmatic thinkers and I think the current process favors defendants in personal injury cases. But, obviously, Judge Sweeney is right that there are judicial economy issues that strongly favor the current process and the mere asking of more questions is not going to weed out many biased jurors.

Thank you to Judge Sweeney for taking the time to share his thoughts with me.

No blog post today on the Maryland Injury Lawyer Blog but I did put up a post today on the Trial Lawyers Resource Center Blog discussing the circumstances under which a videotaped deposition of an expert might be preferable to bringing the expert live at trial. You can access that post by clicking on the link above.

One notable absence from the Maryland Personal Injury Lawyer Help Center has been a sample demand letter, an omission I rectified today. One of my goals in 2008 is to make the Help Center a more complete resource for personal injury lawyers. Most of what we have added in the last year has been by request, so if there is something you want to see, drop me an email and we will put it up. If you have something you want to add to the Maryland Personal Injury Lawyer Help Center, send it to me, and if we think it will be helpful, we will put it up.

(Since I wrote this post last week, I've gotten a number of requests for more demand letters in cases that are not motor vehicle torts. Yesterday, I added second sample demand letter in an products' liability and legal malpractice case.)

I had a jury trial in an auto accident case in Anne Arundel County against State Farm last week. It was a soft tissue injury case with over a year of treatment. It was a case we inherited from another lawyer who retired last year.

The biggest weakness of the Plaintiff's case is that he had few doctor visits before complaining of the soft tissue injury upon which the claim was based. The Defendant's biggest weakness was their liability defense never actually made any sense. The Defendant was, however, very old and very sympathetic. Because the jury is never told insurance is going to pay the claim, you have to expect this to be a factor in the amount of the recovery even if they do suspect there is insurance behind the Defendant.

The jury found for the plaintiff, but awarded only a little over $16,000. State Farm was thrilled, and I was depressed for a few days. They won and I lost. That is how we both saw it and marked our scorecards accordingly. But here's the thing: State Farm only offered $5,000 on the case. It underscores how unreasonable State Farm's offers can sometimes be when it views a jury award of over three times their offer to be a success.

I shouldn't single out State Farm. We have "lost" a lot of trials were the verdict was a great deal higher than the last settlement offer, particularly in smaller cases in difficult venues. (If you are not a Maryland personal injury lawyer, Anne Arundel County is a relatively affluent county whose juries are considered conservative, particularly in cases that involve subjective complaints of pain without any positive diagnostic findings.)

A part of the reason why insurance companies don't feel compelled to make fair offers is because too many personal injury lawyers do not want to try the case - they take the settlement offer. If more personal injury lawyers held the insurance companies' feet in the fire and made them try cases where the offers are unreasonable, we would have many fewer unreasonable offers. Of course, we settle a lot of cases where the offers are unreasonable, because the client does not want to go to trial. But I think too many lawyers convince their clients to settle personal injury cases that really should be tried.

I have expressed my disdain for Maryland’s cap on non-economic damages many times on the Maryland Personal Injury Lawyer Blog. I read an interesting article in the University of Baltimore Law Forum on an issue to which I have never given much consideration: the impact of the cap on non-economic damages on women. In the article, Maryland Tort Damages: A Form of Sex-Based Discrimination 37 U. Balt. L.F. 97 (2007), University of Baltimore law professor Rebecca Korzec argues that the statutory cap on non-economic damages in Maryland, although facially neutral, has the unintended consequence that it disproportionately disadvantages women.

The essential premise is that limiting non-economic damages disproportionately affects female litigants, because women earn less, in large measure due to women spending more time on unpaid child care and taking care of the children and the house. Accordingly, limiting pain and suffering damages does not allow juries to award fair compensation. Non-economic damage caps solidify bias by rewarding economic losses over non-economic ones, intensifying the gender bias of tort law.

Moreover, Professor Korzec notes that physical injuries to women may not result in significant damages awards, because of the nature of some injuries that are specific to women. A "soccer mom" who suffers an injury requiring a hysterectomy, for example, may result in little economic harm. Accordingly, restricting or limiting her non-economic damages may result in an insignificant award of damages.

In my mind, this is one more intellectual dagger into an idea that is not logically defensible. Now it appears that non-economic damage caps are not only discriminatory towards people who are the most seriously injured, it is also discriminatory to women. Although I do not have a lot of hope, the Maryland legislature should really hold hearings on the efficacy of the cap and its impact on a small minority of injury victims that need the system’s protection more than anyone.

(I found this article in the adjunct facility office at the University of Baltimore Law School after teaching my class. I looked on-line at the University of Baltimore Law Forum’s website, but it is not yet available.)

My partner, Laura Zois, and I both received emails last week from people who pointed out that defense lawyers are using the Maryland Personal Injury Lawyer Help Center, specifically some defendants’ motions that are on the site to put the sample plaintiffs’ motions in context. One lawyer expressed a great deal of surprise that this information is provided at no cost.

We do not mind that an unintended byproduct of the Maryland Personal Injury Lawyer Help Center is better educated, better armed defense lawyers. In the big picture, efficiency and justice in personal injury cases are best served when both sides are well prepared. In the information age, there are many resources available to become a better personal injury lawyer and better advocate for our clients. One of the great things about the Maryland Personal Injury Lawyer Help Center is that it is a free resource anyone can use.

Over the next month I’m going to be adding more materials. If anyone has a sample motion, deposition, pleading, or something you think would be of use to the Maryland Personal Injury Lawyer Help Center, send it to me at ronmiller@millerandzois.com. If I think it would be of help, I will post it. If you send the document in Word format, I’ll include a link back to your website, provided you have one and would like me to do so.

One new bill that came out of Annapolis this year, and is set to become Maryland law on October 1, 2007, is aimed at limiting one of the predatory insurance practices: the “don’t hire a lawyer and I’ll give you a quick settlement” tactic. Among the major auto insurance carriers in Maryland, I do not see GEICO, Allstate, or State Farm doing this aggressively or systematically; Nationwide does it a good bit; and Progressive does it with absolute zeal.

This bill will not limit the practice itself but it will give injury victims not represented by a Maryland lawyer the opportunity to void any release signed within 30 days of an accident within 60 days provided certain conditions are met such as providing written notice and, of course, returning the proceeds.

To Progressive’s credit, it does not appear that they are nearly as aggressive in very serious injury cases, but it amazes me to hear from my personal injury clients the lengths to which Progressive will induce quick settlements in smaller cases. Progressive adjusters show up on the injury victims’ doorstep (apparently every adjuster is smiling and friendly) with a checkbook eager to “make this thing right.”

Most Maryland personal injury lawyers do not want to admit this, but while it is always the safest play to contract an injury lawyer after an accident, smaller injury cases can often be settled without a lawyer. Personal injury lawyers do add value to smaller cases but often it is not much more than the contingency fee the lawyer charges. Because insurance companies generally put a value on the quality and reputation of a plaintiff’s personal injury lawyer, I think our law firm adds value well above our fee in small personal injury accident cases. But do you need to hire our law firm or another lawyer in smaller cases? I think it depends on the case but, often, the answer is no.

I certainly have respect for Progressive as an insurance company. I like almost all of their adjusters and I do not think this “quick settlement” practice is unethical; however, in my opinion, Progressive is the last insurance company I would expect to make a reasonable offer in a “quick fix” situation. If I were to give all of the major insurance carriers in Maryland the exact same case, I would expect Progressive’s offer to be the lowest. It is generally a struggle for accident victims with or without personal injury lawyers to get Progressive to offer fair value without filing a lawsuit.

Early on in the development of the case point no one knows the actual value of the case because the extent of the injuries and the harm from those injuries is still unknown. Accordingly, almost invariably, any early settlement is imprudent. Why do people take a quick settlement then? Because some injury victims are either naïve or they need money fast. Arguably, then, this new Maryland law could go further and make all quick settlements voidable. To what extent should society protect people from themselves? This is a political and philosophical question beyond the scope of the Maryland Personal Injury Lawyer Blog, but I think this law probably strikes the right balance by providing some protection for accident victims while also giving insurance companies some ability to rightfully be able to settle smaller personal injury claims without waiting for an indefinite period of time before they can close the claim.

It is a slow blogging week. I will relock and reload after Labor Day. I did write two blog posts for the Trial Lawyer Resource Center on loss of consortium claims that you can access here and here.

One-hundred percent of our law firm’s practice is personal injury cases. We do not and will not take any defense cases even if we believe in the defendant’s case. Yet, last year I found myself on the other side of the coin as a defense expert. I served as a legal malpractice expert for a local defense firm on behalf of a plaintiffs’ personal injury lawyer in Towson. I believe this lawyer did not breach the standard of care according to his version of the facts (and, parenthetically, I believe the most logical version of the facts). Certainly, in this case, under the Plaintiff’s version of the case, the lawyer committed legal malpractice.

While I did not have the slightest trepidation about taking this case or the expert opinions I expressed, it was certainly an odd experience to be back on the defense side for the first time in over six years. Regrettably, from an experience standpoint, the case settled before I had the opportunity to be deposed. It would have been a particularly educational experience, because the legal malpractice lawyer who would have deposed me is a skilled and well prepared lawyer, who would have been effective in challenging my opinions. Taking a different role in a case certainly does change your perspective, and I think helps you think more creatively about your cases. (Similarly, I have been a law professor for over 10 years. It would be interesting to be a student again after all of the exams I have graded over the years. I think being a professor would make me a better student.)

Believe me, I am all in favor of plaintiffs’ personal injury lawyers suing other personal injury lawyers when one of us has breached the standard of care. The whole idea of lawyers "sticking together" is both absurd and wrong. Our lawyers handle legal malpractice cases where the underlying case is a catastrophic personal injury case. But I also think there is an obligation to be willing to come forward and testify on behalf of a fellow personal injury lawyer if you believe the lawyer has not breached the standard of care and committed legal malpractice.

The Maryland Trial Lawyers Association Auto Negligence section is having a seminar Friday, September 7, 2007 in Columbia, Maryland at the Hilton Hotel. The subject of the seminar is bad faith law in Maryland with a focus on the new first party bad faith law. The following Maryland lawyers/judges are expected to speak:

Robert J. Zarbin (The Jaklitsch Law Group in Upper Marlboro, Maryland)

Thomas E. Dewberry (Chief Administrative Law Judge, Maryland Office of Administrative Hearings headquarters in Hunt Valley, Maryland)

Irwin E. Weiss (Law Office of Irwin E. Weiss in Baltimore, Maryland)

Lawrence M. Schultz and Mark Jenkinson (Burke, Schultz, Harman & Jenkinson in Martinsburg, West Virginia)

Michael Weiss (Weiss & Saville, P.A., in Wilmington, Delaware)

James R. Ronca (Anapol Schwartz in Philadelphia, Pennsylvania)

If you are a Maryland personal injury lawyer and you have not joined the Maryland Trial Lawyers Association, you should do it today. If you are handling automoblie accident cases, you should join the Auto Negligence section as well.

Last week, a well respected defense lawyer told one of our lawyers that they had obtained the Maryland Trial Lawyers Association's “Handbook," which spells out the terms for a defense requested medical examination. This "Handbook" has made its way into a Motion to Compel a Physical Examination, specifically including this "MTLA Handbook" as an exhibit to the motion. By way of this inclusion, I assume this is an authoritative source of legal guidance for the court on this discovery matter.

Now back to reality. Maryland Trial Lawyers Association does not have a "Handbook" on defense medical exams. Instead, it is just a copy from the Maryland Personal Injury Lawyer Help Center of the link from our website setting forth our suggested conditions for a defense medical exam. I think it is funny that this is being represented as some sort of guide to fighting medical exams. I am glad people are using the Maryland Personal Injury Lawyer Help Center. My partner told me last week that a defense lawyer she spoke to said they often get motions from other lawyers copying our sample motions. The lawyer said they call them "Miller & Zois" motions.

There is also a motion for sanctions for failure to appear for a scheduled medical exam. As I indicated earlier, my law firm likes and respects this lawyer and his firm, but this motion really annoys me. I could throw out 5 reasons why, but only one really matters.
In Maryland, and also under the Federal Rules of Procedure, a defense medical exam is not a matter of right and may be obtained only by an order from the court.

So let's get this straight: Defendant's lawyer sets a date for a DME, unilaterally by the way, just assuming the Plaintiff has no life and lots of time on her hands, for which the lawyer has not obtained a court order, and then files a motion to compel when she does not present for the medical examination. Huh? The motion also fails to mention that the discovery deadline - by which time all discovery disputes should be resolved - has long since passed.

I wrote a blog post today for the Trial Lawyer Resource Center regarding an article I read in the Maryland Daily Record titled "Beware of Bow Ties and Diamonds in Court." You can access it here.

I spent a good bit of time this weekend making additions to the Maryland Personal Injury Lawyer Help Center. What I have done is pull up old emails that requested forms/documents that we have (and forwarded to the requester) but did not have a category on the PI Help Center that really fit the document. So I added a miscellaneous forms and letters category. So far I have added (1) Sample Release, (2) Sample Retainer Agreement (the most requested), (3) Sample HIPPA Authorization, (4) Sample Lost Wage Form, (5) Sample AISG Form (to get client's claim history), (6) Sample Personal Injury Intake, (7) Sample Request for Traffic Light Sequence Report, (8) Sample Affidavit of No Insurance, and (9) Request for Judical Notice as to Time, Speed and Distance.

If there is something you need you think our lawyers may have, let us know and I will be glad to send it to you. The readership of the Maryland Personal Injury Lawyer Blog has gone up dramatically in recent months and it is pretty much impossible to play phone tag with everyone in order to find out the document you seek. Please contact us with any requests through the contact form on this blog or email me at ronmiller@millerandzois.com.