Here are some best practices to follow when creating your medical case chronology that will help you make the best use of these chronologies.

1. Medical Case
Chronology – Best
Practices
Here are some best practices to follow when
creating your medical case chronology that will
help you make the best use of these chronologies.
Medical Record Review

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A medical case chronology is a repository of facts and provides tremendous support when you
are preparing for trial. It is the best way to understand the case because it presents the medical
events as they occurred. They are detailed timelines of the events and highlight specific charges
and possible areas of liability. The greatest advantage of having a well-organized chronology is
that it helps you organize your thoughts and arguments clearly. They help identify all the vital
facts pertinent to a case, facts that may be disputed and those that will be accepted in court.
Moreover, it is a great tool to disseminate knowledge of the case among your team members.
The amount of information attorneys have to handle is huge, which makes sorting it and
bringing some semblance of order to the scattered data almost next to impossible. This is
where modern technology can provide the necessary support. The focus needs to be on
capturing significant information – only then will the chronology be really valuable.
Ensuring Value for Your Medical Case Chronology
There are some best practices you can follow to make sure that you have a working chronology.
 Make sure to start preparing the chronology at an early stage itself so that you can
capture the details in order from the very beginning, and not miss out on any crucial
details.
 As you develop it, consider whether the facts listed in it clearly reveal your client’s
awareness of the case. Try to fill in any missing dates; if this is not possible, try to locate
witnesses/documents that may act as source for such vital information. Whether
favorable or unfavorable, an accurate medical chronology should contain all facts.
 Sometimes attorneys work with document indexes or a listing of all records relevant to
the case rather than a chronology. This can create problems in presenting the case
clearly. It is better to work with a chronology that lists all the facts, with proper
reference to the appropriate medical records.
 Include all facts – those that are probable and those that are disputed so that you have
all facts at your fingertips without the risk of leaving something out.
 Consider using database software instead of word processing software because this is
the easier way to create and maintain your chronology. A multiuser database will allow
your team members to enter, edit and research the facts concurrently. Another
advantage is that it automatically sorts all facts by date. More importantly, the name of

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the individual entering /modifying the data is automatically stamped. Database software
will facilitate searching your chronology and coming up with the required facts quickly.
 Make sure that the names you use are consistent. The same entity may be referred to
by several names. For example, Kristen Memorial Hospital may be mentioned variously
using the terms, KMH, KM hospital, Kristen and so on. To prevent any confusion that
may result from such usage, ensure that you use a single alias for a particular hospital,
such as KMH for the above hospital. You can create a dictionary listing such aliases, and
have every team member refer to it when making entries.
 When dates are obscure, consider putting a question mark for the portion of the date or
time you are unsure about. For example, September of 2000 can be expressed as 9/?
/2000, when you are not sure what the date is. This will highlight the portion you need
to check out and clarify. When you obtain the information, you can include that in the
place of the question mark. This will work with word processor software and also with
some database packages specifically designed for litigation data entry. Many database
packages do not allow incomplete entries. So what to do when you are using database
software? Leave the date cell blank when you don’t have the required information, or
complete the date format using an approximate complete date such as 9/3/2000, when
you know that the fact happened sometime in September. When you get the correct
information, you can update the time, date and so on.
Medical case chronologies can be used to present a powerful case to both judge and jury. You
can use them to inform the jury about the vital facts and substantiate your argument. Make the
best use of this knowledge base of facts when preparing for depositions, in settlement
conferences, when developing motions for summary judgment and pretrial motions and during
trial.