1. A New Intern Guide to Properly
Conducting Personal Injury Cases
(Pre-Trial)
By: Imani Cabassa

2. Table of Contents
I. Objective of the guide
II. Conducting the Initial Interview
III. Notifying insurance companies
IV. Requesting Information/ Collecting Evidence
a. PIP Claim
b. Medical Records
V. Organizing Client Folders
VI. Conducting the Negotiation of matter
a. Demand Letter
VII. Finishing a Settlement
VIII. Resources

3. I. Objective of the Guide
The objective for this manual is to give new interns a proper guide on how to
successfully organize personal injury cases for Mr. Shakur. This manual will provide
directions on how to complete each of the tasks Mr. Shakur will ask when working with a
personal injury case.
These tasks may include conducting an initial interview. They will also include
notifying the insurance companies, requesting information and collecting discovery,
organizing the client’s folder, and many other topic. Each of these tasks will be
thoroughly explained. They will be given step-by-step protocol on how they should be
implemented.
Even once an intern is familiar with the steps on conducting personal injury cases,
this guide can still be used as a reference to make sure their work is done correct. In the
future, this guide can be updated and refurbished, as rules and regulations might change.

4. II. Conducting an Initial Interview
Clients will usually seek help of an attorney, after they have been involved in an
accident. In order to seek help, clients will usually call the office requesting to speak to
Mr. Shakur. One of the first important steps is to set up an initial interview. The interview
is so that they are able to come in and talk about the accident in a face-to-face setting. It
will help Mr. Shakur decide whether or not he should take the case. The interview will
also explain more about the details of the accident. (Banks)
Setting up the interview:
As a new intern, upon receiving the first call from a client seeking help, it is important
that you set-up the initial interview. The following will ensure that you set up the
interview correctly.
1. Answer the phone with a friendly greeting.
a. Ex. “Good morning, this is Shakur law, how may I help you.”
2. Respond to the client with their questions and/or concerns; offer them to come
into the office for a free consultation with Mr. Shakur.
a. Make sure to properly address their concerns by being sincere and
emphasizing with them.
3. Ask them what date and time works well for them. Then compare the date and
time with Mr. Shakur’s schedule to make sure he is free and available that day.
4. Make sure that you properly confirm it with them, once you and the client have
both come to a consensus on what day is best for the consultation.
a. Ex. “I have you scheduled for Friday, April 19th, at 2:00PM”
b. Make sure you write this time and date down in the appointment book so
that Mr. Shakur will not double book himself.
5. Take down the information of the client.
a. This includes:
i. Name
ii. Phone number
iii. What type of accident it was
6. Make sure the client knows the exact location and the directions to the office,
before ending the phone conversation.
a. This step is important because we want to ensure the client will not get
lost or miss an important because of lack of knowledge.
7. End the phone conversation on a positive note, once everything has been
confirmed, thanking the client and once again confirming the date and time that
the consultation will occur.
a. Ex. “Thank you again for calling, we look forward to seeing you this
Friday, April 19th at 2:00PM. I hope you have a great day.”
After the phone call with the client, inform Mr. Shakur of the appointment that has been
made. Make sure you share the clients’ information with him so that he is able to prepare
the proper questions for the interview.
On the day of the interview, when the client first comes in be sure to greet them
and offer them cold refreshments. This is important to ensure that the client is
comfortable and to allow him/her to feel like we are trustworthy people.

5. During the interview, Mr. Shakur will usually allow the intern to sit in with him and
observe. The following steps should be taken when observing the interview:
1. Sit quietly and listen closely.
a. This is important incase Mr. Shakur ask if there is any details that he
missed in his notes.
2. Write notes
a. Be as detailed as possible to answer any questions Mr. Shakur might
have for you while you were observing
b. Writing notes can also consist of writing questions that you may have
about some of the information that the client is given.
3. Use Google street map view when needed.
a. Sometimes clients have a hard time describing where the accident took
place. The use of the Google street maps allows Mr. Shakur to pull up
the exact location so that everyone can get a general sense of where
the accident occurred, how it might have happened and other general
information.
After hearing the case, Mr. Shakur will decide if this is case worth taking. He will then
talk to the client about what he will charge and have them sign a contract. As in an intern,
there is minimal task involved with the agreement between Mr. Shakur and client.
However, one might be asked to begin a new client personal injury folder, as well as
writing a notification to the insurance companies to let them know Mr. Shakur will now
be representing the client.

6. III. Notifying Insurance Companies
Once a client has signed the contract agreeing that Mr. Shakur will be
representing them in their matter, the next step is to notify the insurance companies. It is
important to notify insurance companies that Mr. Shakur will now be representing the
client and all information, questions and concerns should be brought up to him rather
than addressing the client. It is custom that we notify the insurance companies of both
parties, to ensure that each company knows exactly what is going on. Faxed or mailed
letters are usually the easiest way to notify the insurance company.
Mr. Shakur will ask you to write the insurance company a letter in order to notify
them that he will be the client’s representation from now on. The following steps should
be completed when notifying an insurance company:
1. Follow a template of a past notification letter to ensure that formatting
is correct.
2. Begin by addressing the insurance company, of who Mr. Shakur is and
what this letter will involve.
3. Give the clients name, claim number, and background of accident.
a. It is important that if the claim number is not already known that you
reach out prior to find out what it is, as well as the name of the claim
adjustor working with that case.
4. Request PIP information if that is a part of the insurance company
coverage.
5. Conclude letter by letting the insurance company know your next steps
of action in order to proceed.
Once all of these steps are completed, a draft of the letter should be given to Mr.
Shakur so that he is able to read over your work. He will read it to make sure everything
is covered and that there are no spelling errors. Once the letter is thoroughly checked
over, Mr. Shakur will sign and give permission to send it over. Interns have the option to
fax or mail over the documentation. To ensure delivery, it is recommended that both
methods of delivery be performed. (Shakur)

7. IV. Requesting Information/ CollectingEvidence
A. Requesting a PIP Claim:
After the notification letter is sent to insurance companies, informing them of the
client’s representation the next step is to request information and collects evidence.
Depending on the type of accident, as well as the clients insurance companies, one of the
first pieces of information that will be collected is the documentation for a PIP claim.
PIP stands for Personal Injury Protection and is given by the client’s insurer for payments
of medical bills and lost wages (Goguen). Usually, the client’s insurer will pay their
medical bills and compensate for lost wages up front. However, Mr. Shakur being the
client’s representation, it is responsible for requesting this claim from the insurance
company. Some clients may not have PIP coverage with their insurance plan so make
sure that this is discussed with the client before request is made.
If client has PIP coverage, follow the following steps to request a PIP claim:
1. Follow a template of a past notification letter to ensure that formatting
is correct.
2. Address insurance company claim adjuster, as well as tell the
reasoning for writing this request.
a. Include clients name, date of accident, claim number
3. Give background information on accident.
a. This should include what happened during the accident, how
the client was injured, and the medical attention that was
sought after accident.
4. Inform insurance company of the amount of the medical bills, as well
as lost wages due to accident.
a. Claim adjuster will want to see actual copy of medical bills, so
attach them at the end.
b. Explain how the client has lost wages.
i. I.e. “ Due to Joe Smith’s accident, he has strained his
shoulder and is unable to perform his task at work.
Therefore, he has been unable to work and earn money”
ii. This example shows that because of Joe Smiths
accident, he is unable to work and provide income and
therefore has lost wages.
5. Request the proper amount for PIP claim and where it can be sent
6. Conclude by stating where attachments of medical bills are located.
7. Give additional contact information, incase adjuster needs to discuss
more details with Mr. Shakur.
After the request of the PIP claim letter has been written, it should be given to Mr.
Shakur. He will then go over as before with the notification letter, in order to ensure
everything is written correctly. He will then sign the letter to make it official. Once the
letter has been edited and signed, it will be ready for delivery. One copy should go to the
client, while the other copy goes to their insurance company. Again there are two
methods of delivery for this letter, it can be faxed to the insurance company, as well as

8. mailed out to them. It is recommended that both methods of delivery be performed.
(Shakur)
B. Requesting Medical Records:
Following the request for the PIP claim if applicable, the next step would to be
request the medical records from doctors who have diagnosed and treated patients.
Medical records can be used as evidence because they will state the injuries of the client
because of the accident. They will also help determine cost of meeting with doctors, and
amount spent in treatment. Before medical records can be requested, a similar notification
of representation (like with the insurance company) must be sent to the doctor. The
doctors must know that Mr. Shakur is representing the client in order to release the
client’s medical information.
The notification and request of medical records can be combined into one letter.
To write the following notification and request letters follow the following steps:
1. Address the doctor.
a. Do not use general greetings such as “To Whom It May
Concern”
2. Introduce Mr. Shakur and explain that he is representation for client
who was involved in accident.
3. Explain the accident of the client and what Mr. Shakur will be trying
to do with the matter.
a. This will be briefly explaining Mr. Shakur’s plan of action.
4. Request for all medical records of the client after the accident, relating
to the accident.
a. This will help prove treatment and diagnoses to insurance
companies.
5. Attach a HIPAA form with this letter of request.
a. A HIPAA form protects the privacy of a client and it is a
standard form sent in with the initial communication of client’s
doctors.
6. Conclude the letter with the contact information of Mr. Shakur.
a. This is so the doctor will be able to reach Mr. Shakur if needed
for questions, comments and/or further validation.
Similar to the last three letters, Mr. Shakur will review the notification and
request letter to the doctor. Once he has made proper corrections and finalizes the letter,
he will then sign it to make it official. Once the letter has been edited and signed, it will
be ready for delivery. One copy should go to the client*, while the other copy goes to the
doctor. Again there are two methods of delivery for this letter, it can be faxed to the
insurance company, as well as mailed out to them. It is recommended that both methods
of delivery be performed.

9. *It is important to continue to give clients copy’s of everything that is sent on
their behalf. This allows them to feel that they are still in the loop of their case. It
also show’s them how hard Mr. Shakur is working for them, building a stronger
trust relationship between attorney and client.

10. V. Organizing Client Folders
After the client signs the agreement stating that Mr. Shakur is now their legal
representation, a folder is made to keep all documentations on their behalf. This includes
copy’s all notifications letters, PIP claims, medical records and any other documentation
sent on the client’s behalf. As an intern, it is important to keep these folders organized
and neat so that any time, Mr. Shakur can pull the file and look for the documentation he
may need at the time. Personal injury folders are always the green folders. This helps
determine the difference between the criminal cases (blue folders) and the personal injury
folders (green).
There is a sample folder in the bottom right hand drawer in the desk that sits
outside of Mr. Shakur’s office. This folder will assist when filing documents. However,
the following is how the folder should be organized.
I. Documents included in the first left inside panel of folder.
a. Retainer agreement
i. Signed contract between client and Mr. Shakur that
guarantees representation.
b. Personal injury summary.
i. Summary of the accident and how the client was
injured
c. Letters to clients.
i. Any personal letters Mr. Shakur has sent to clients.
ii. Letters sent from insurance companies to clients.
d. Action log
i. Action log is all the actions listed when trying to solve
the matter and the dates these actions occurred.
II. Documents included in the first right side of the panel.
a. Anything sent from the office on the client’s behalf.
i. This includes the notification letters to insurance
companies, the request for medical records and the
request of any other records.
b. Medical bills
i. Emergency room fees
ii. Fee’s from seeing the doctor
iii. Fees from treatments
iv. Fee’s involving equipment used
1. I.e. MRI’s, X-Rays
c. Vehicle estimates.
i. Fee’s from riding in ambulance
d. Wage statements
i. Show how much client was making prior to accident
e. Wage Lost
i. Show how much clients lost because of accident
f. PIP form.
III. Documents on the next side of the folder.
a. Medical statements
i. Includes diagnoses and treatment procedures

11. ii. Anything that goes to insurance.
IV. Documents on outermost right side (last page).
a. Any documents from opposing counsel
b. Defendants Insurances
c. Medical Records
i. Oldest on top, most recent in the back.
Organization of the client’s personal injury folder allows for a more accessible
way to look up documentation when needed. As an intern, keeping these folders clean
and organized will keep everyone on the same page and make communication between
the client and Mr. Shakur easier. If ever lost refer back to the sample folder located in the
bottom right desk drawer outside of Mr. Shakur’s office.

12. VI. Conducting Negotiation of Matter
Negotiation is by far one of the most important factors in a personal injury
case. It involves going back and forth with the defendant’s insurance company in
order to settle on case before taking it to trial. One of Mr.Shakur's goals is to try
and settle the case through negotiation rather than taking it to court where it will
go through a long strenuous process.
Negotiation involves a lot of back and forth communication between the
insurance company and Mr. Shakur. Once the demand letter is sent, the insurance
company and Mr. Shakur will go back and forth trying to settle the case. If the
case cannot be settled through the negotiation, the case will proceed to a trial.
A. Writing the Demand Letter
The first step in the negotiation process is sending a demand letter to the
defendants insurance company. The demand letter involves the request of what
your client is willing to settle the case with, as well as other evidence found while
collecting evidence.
The following steps should be used when writing the demand letter:
1. Begin with the address and date.
a. Address of the insurance company and date that
the initial demand is sent.
2. Subject
a. This will give a brief title for the purpose of the
letter.
3. Introduction paragraph.
a. Use this paragraph in order to discuss client’s
basic background information.
b. It should contain information such as the clients
name, age, employment, a description of the
client’s life-style before the accident, date of
accident and a brief description of the accident
and how it has affected the client.
4. Background on accident
a. This is where you should describe the accident
i. Give every single piece of information on
the accident. Include:
1. Where it occurred
2. The diagnosis of the client
3. The treatments the client has had
to go through
4. Life-style changes the client has
had to make because of the
accident
5. Everything they had to try to
alleviate pain
5. Information on medical treatments

13. a. In this section list all the medical treatments.
Give a brief description of them as well.
b. You will have to attach the copy of treatments to
the back of the letter as well.
6. Chart on medical diagnoses
a. In this section you will make a chart of medical
diagnoses. The chart will be similar to the one
below:
ICD-9 Code Date Noted Physicians
b. The ICD-9 code is an international code used by
insurance companies, physicians and hospitals to
diagnose a patient. The use of these codes keeps
everyone on the same page.(ACEP ICD-9 FAQ)
c. The date noted would be the date the diagnoses
were given.
d. The physician would be who diagnosed the client
for that specific injury.
7. Describing the pain, loss and sufferings.
a. Within this section, you need to describe in
details all the pain, loss and sufferings that the
client has had.
b. It is important to describe this with the greatest
detail and really convince the insurance
company of what the client had to go through.
8. Listing the expenses of medicals
a. The next step would involve listing the medical
expenses
b. Include all visits, ER stays, treatments, and use of
machines cost.
c. At the end of this section include the total
amount of medicals.
9. Information on damages
a. Describe in detail, the damages that occurred.
10. Explanation of liability
a. In this section, explain how the defendant was
liable.
b. List the defendant’s faults in the accident and
relate it back to being the cause of the client’s
injuries.
11. Conclude the demand letter

14. a. The conclusion of the demand letter will focus on
summing up the entire letter.
b. At the end of the conclusion, there needs to be a
request for the amount of money the client is
asking for.
The demand letter will also require the approval of Mr. Shakur. He will have to
read over it to edit and make sure all the information is correct. He will then sign the
letter and it will need to be sent off to the defendants insurance company. Again as with
every letter, a copy will need to be given to the client. The methods of delivery will also
remain the same. They should both be applied in order to ensure that they are received.

15. VII. Finishing the Settlement
Settlement occurs when both parties agree on the amount that should be
given to the client for their injuries pain, loss and sufferings. Mr. Shakur will
handle the majority of everything that is involved in between the negotiation stage
in the settlement. As an intern, settlement involves calling the client to inform
them of the settlement procedures.
After Mr. Shakur has settled the case, call the client to inform them of
what the case has been settled as. These are the following steps:
1. Call the client.
2. Inform them that their case has been settled.
3. Give them the amount that the case was settled.
4. Inform when they can come in to sign the check and go over
the rest of the settlement procedures by scheduling a date when
they can come see Mr. Shakur.

16. VIII. Resources
1. "ACEP ICD-9 FAQ." CLINICAL PRACTICE AND MANAGEMENT. American
College of Emergency Physician, 16 Apr. 2015. Web. 6 Dec. 2015.
<http://www.acep.org/Clinical---Practice-Management/ICD-9-FAQ/>.
2. Banks, Ronald, and John TARATINO. Personal Injury Forms: Discovery and Settlement 1
(2007). Print.
3. Goguen, David. "PIP (Personal Injury Protection) Claims After a Car Accident -
AllLaw.com." AllLaw.com. 2015. Web. 6 Dec. 2015.
<http://www.alllaw.com/articles/nolo/auto-accident/pip-personal-injury-
protection-claims.html>.
4. Shakur, Malik. "How to Conduct Personal Injury Cases." Personal interview. 15
Nov. 2015.