Arnold O.

Personal Injury Law Firm| California, United States Position: Case Manager ⸻ INSURANCE AUTOMOTIVE ACCIDENT CASE PROCESS: PRE-LITIGATION STAGE (Initial Intake to Negotiation) 1. Client Intake & File Setup •Send out new client retainer packet to client for e-signature. •Confirm Plaintiff’s declarations page is in Dropbox. •Confirm Plaintiff’s UIM limits are added to CasePeer. •Open claim with 1st party insurance carrier. •Open claim with 3rd party insurance carrier. •Fill out Plaintiffs’ insurance info, including claim number and policy number. •Fill out Defendants’ insurance info, including claim number and policy number. •Send LOR(s) to both insurance firms. •Confirm acknowledgment from Plaintiff’s insurance to our LOR is in the file. •Confirm acknowledgment from Defendant’s insurance to our LOR is in the file. •Run limits search on Defendant’s policy through Pacific Liability. •Confirm Defendant’s policy limits are added to CasePeer. •Verify if liability has been accepted or denied. Please update file. 2. Evidence Collection •Verify we have accident scene photos in the file. If not, call client to request. •Verify we have injury photos in the file. If not, call client to request. •Obtain Plaintiff’s vehicle’s PD estimate. •Prepare traffic collision report request to be mailed out along with payment. 3. Medical & Insurance Tracking •Call client to review medical providers. •Review & request pending medical records. •Call all medical providers to verify outstanding medical bills match those added to CasePeer. •If client went to hospital, verify who paid the hospital bill. •Submit Medi-Cal and Medicare claim forms to rule out statutory liens. •Call client to follow up on medical treatment. DEMAND & NEGOTIATION STAGE 4. Demand Process •Draft & review the demand with the client. •Send demand to adverse carrier. •Confirm receipt of demand with carrier. Attorney’s advice needed: •Call the client with an offer and recommend a counteroffer. •Send the counteroffer to the insurance company. LIEN RESOLUTION STAGE 5. Lien Negotiation & Case Closeout •Re-assign case to lien negotiator for handling. II. LITIGATION STAGE 6. Complaint Filing •Draft Complaint (including statement of jurisdiction, damages, prayer for relief) •Research and list proper parties & causes of action (Negligence, Premises Liability, etc.) •Review & cite relevant CACI jury instructions or case law •Prepare Civil Case Cover Sheet (CM-010) •Prepare Summons (SUM-100) •File complaint with appropriate Superior Court •Calendar case deadlines (responsive pleading, proof of service, etc.) •Arrange for service of Summons & Complaint 7. Discovery Phase •Draft & serve: oForm Interrogatories oSpecial Interrogatories oRequests for Production of Documents oRequests for Admission •Review and calendar discovery deadlines (per CCP § 2024.010) •Prepare subpoenas for third-party records (e.g., medical providers) •Track receipt and review of discovery responses •Meet & confer if responses are deficient •Propound supplemental discovery if needed 8. Law & Motion Support •Conduct legal research (Westlaw, Lexis, CEB) •Draft motion documents: oMotion to Compel oMotion in Limine oMotion for Summary Judgment (if applicable) •Prepare supporting declarations and exhibits •Assist in drafting Oppositions & Replies 9. Depositions •Schedule Plaintiff, Defendant, and witness depositions •Prepare Notices of Deposition and subpoenas (if needed) •Coordinate court reporters and interpreters •Prepare deposition summaries for attorney 10. Trial Preparation •Prepare Trial Binder •Organize evidence, exhibits, medical records •Draft Trial Brief (if requested) •Create witness list and exhibit list •Draft jury instructions and verdict forms •Assist with trial subpoenas and logistics 11. Post-Trial & Settlement •Prepare Settlement Agreement & Release •Draft Dismissal (CIV-110) •Ensure liens are satisfied and settlement is disbursed •Archive and close the case file