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Motor Vehicle Medical Records

Location:
St. Louis, MO
Posted:
January 09, 2024

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Resume:

RESUME`

Thomas J. Kavanaugh

Attorney at Law

St. Louis, Missouri

The Kavanaugh Law Firm

314-***-****

Professional Experience.

****-****: The Kavanaugh Law Firm.

A general practice, advising clients on various legal matters.

Focus remains trials and hearings.

Venues:

a) State and federal courts.

b) Government agencies (Social Security Administration

and Department of Veterans Affairs).

Representative cases:

Bodily injury, motor vehicle accidents, slip and fall, trustees, contracts, corporate

responsibility, and general liability.

Trial Preparation by Plaintiff’s Counsel

Facts: Client is the plaintiff injured in an automobile accident. She

claims her injuries were caused by defendant’s negligent driving.

Witnesses. Initial interviews with client and other witnesses.

Photographs. Obtain pictures of scene of the accident and damaged vehicles.

Medical records. If emergency medical treatment rendered, obtain those records. .

Initial conference with insurance adjuster. Exchange thoughts about case.

Request copies of documents from his file he is willing to provide.

Thomas Kavanaugh Resume`

(continued)

Conferences with client (ongoing). Keep client informed of case status.

Defendant’s driving history. (Missouri Department of Revenue).

. Further meeting with insurance personnel. Further discussion about

liability and settlement value. Provide documents showing defendant’s

negligence and plaintiff’s injuries

Follow-up interview of client. Case moving along. Discuss her injuries,

her pain, and disability. Review her expected financial damages (lost

wages, medical expenses, motor vehicle damage).

Legal research. Ongoing.

Meeting with physician. Get specifics on client’s condition: parts of

body injured, treatment, medication, likelihood of full recovery, any

remaining medical problems, and need for future medical treatment.

Client’s economic losses. Obtain from client records of her financial

losses: wages, non-covered medical expenses, automobile repairs, cost of

items plaintiff can no longer handle (eg, transportation and house cleaning).

Settlement demand letter to adjuster.

Client follow-up conference. Case status report.

Meet with colleagues. Discuss settlement value.

Meet with adjuster. Insurance company tenders final settlement

offer. Client refuses offer. Trial necessary

.

Plaintiff’s additional preparation when suit Is necessary.

Pleadings. File petition and interrogatories.

Motions. Prepare as needed.

Case management conference.

Expert witnesses. Retain, if applicable.

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Thomas Kavanaugh resume`

(continued)

Court hearings. Attend and submit supporting legal memoranda.

Responses to discovery requests. File promptly. Ensure that

defendant does the same.

Depositions.

Final meeting with all witnesses. Discuss trial testimony

Witness list.

Trial brief.

Jury instructions.

TRIAL.

Personal Skills

Attentive to detail.

Excellent communication ability.

Motivated.

Comfortable negotiator

Work well with clients, witnesses, opposing

counsel, and with team members.

EDUCATION. Washington University School of Law.

Doctor of Jurisprudence

Recipient, E. Marion Foundation Award.

BAR ADMISSIONS. The Missouri Bar.

The United States District Court for

the Eastern District of Missouri.

PROFESSIONAL The Missouri Bar Association.

ASSOCIATIONS. The Lawyers Association of St. Louis.

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