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Deepesh P.

Deepesh P.

Personal Injury Paralegal | Demand Letters, Med Records, Discovery

I build personal injury demand packages and medical chronologies for U.S. law firms. Give me the raw file — records, bills, crash report — and you get back attorney-ready work product, not a rough draft you have to rebuild before you can send it. I'm a qualified lawyer (LL.B., National Law University Jodhpur) with 3+ years supporting U.S. plaintiff firms in personal injury, medical malpractice, class actions, and complex civil litigation. PERSONAL INJURY DEMAND LETTERS & SETTLEMENT PACKAGES A demand is not a summary of medical records with a number at the end. It's an argument. I build the liability narrative from the crash report and the scene facts, tie every claimed injury to the treatment that documents it, pull the objective diagnostic findings an adjuster can't argue away, and structure the damages so the number at the bottom reads as inevitable rather than aspirational. Demand types I draft: Auto and motor vehicle bodily injury demands Policy-limits demands, including Stowers (Texas) and Hovet (New Mexico) framing UIM/UM demands, including Declaratory Judgment Act and attorney's-fee exposure sections Commercial vehicle and trucking demands — respondeat superior, negligent hiring, training, supervision and entrustment, FMCSA violations, gross negligence Premises liability demands Government entity demands under the Texas Tort Claims Act PIP and Med Pay demands Multi-claimant and family demands, including split-limit coverage analysis Supplemental demands following additional treatment Every package includes the liability section, a chronological treatment summary by provider, an objective-findings summary, an itemized bills table, future care, the non-economic damages narrative, the demand and deadline, and a clean exhibit index. MEDICAL RECORD REVIEW & CHRONOLOGIES Hand me 600 pages and you get back something usable for evaluation, demand, deposition, or mediation: Medical chronologies with date, provider, finding, and record cite Treatment summaries, diagnosis summaries, procedure summaries Medical record indexes and Bates-referenced timelines Imaging, EMG, and diagnostic testing summaries Medication histories, symptom and limitation summaries, prognosis Future treatment needs and life-care-plan inputs Prior and subsequent treatment relevant to causation and apportionment Treatment gaps and pre-existing conditions flagged before the adjuster finds them Delivered in Excel or Word. On multi-claimant cases, a separate sheet per claimant. DISCOVERY & LITIGATION SUPPORT Interrogatories, RFAs and RFPs. Discovery responses with tailored objections. Meet-and-confer letters. Complaints, answers, and responsive pleadings. Declarations and proofs of service. Deposition summaries and witness outlines. Discovery calendaring, deadline tracking, and case timelines. CALIFORNIA LITIGATION Code of Civil Procedure research, multi-county e-filing through InfoTrack, discovery deadline management, and litigation coordination. SOFTWARE & PLATFORMS Legal research: LexisNexis · Lexis+ Protégé · Westlaw AI / CoCounsel · Casetext · Google Scholar E-filing: InfoTrack, multi-county California Documents and deliverables: Microsoft Word · Microsoft Excel · PDF AI-assisted review: ChatGPT · Claude I use AI for large-document review, extraction, summarization, issue spotting, and research assistance. It makes me faster on volume work. It does not make the judgment calls. Nothing leaves my desk that I haven't verified against the record — if a citation is in your document, I checked it. EXPERIENCE 3+ years supporting U.S. law firms 200+ deposition and medical record summaries 100+ discovery responses and pleadings 50+ California e-filings WHY FIRMS KEEP SENDING ME WORK You shouldn't have to explain an assignment twice. I read the file, work out what the deliverable actually needs to be, flag what's missing before it becomes a problem, ask the one or two questions that matter, and deliver on the date I gave you. I'm set up to own a piece of a caseload, not just a single task. On scope: I hold a law degree but am not licensed to practice in the United States. Everything I produce is attorney-supervised work product and litigation support, not legal advice. Your name goes on it. My job is to have it ready and right when it reaches you. Send the case file, the records, or the assignment, and tell me the deadline. I'll come back with questions if I have them, and the finished work if I don't.

🇮🇳Jaipur, India$20/hr100% JSS3.63 (12)Since Jan 2022

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