Car Accidents — Initial injury lawyer meeting — Take-Home Instructions

Some personal injury lawyers will give you a written handout that will give you take-home instructions about what you should do to help your lawsuit.

If your lawyer uses take-home instructions they may include some of the things in the sample provided here.


Read this list over tonight at home.
Also, read this list over a week from today.
Just before you see us the next time, use this list as a checklist of what to bring to us then. (Your next appointment to see us is on ______________.)


  • Do not discuss your case with anyone except our office. Keep in mind that anything you say is something that may be used against you in the settlement of the case. If anyone wants information about your case, politely tell them: “My attorney told me not to say anything about the case.” Tell the person who wants information about your case to contact us.
  • Do not sign anything about your case except what we send to you, or that we discuss with you before you sign it.
  • Bring us your driver’s license, so we can make a copy of the front and back.
  • Bring us any photographs you have of the vehicle, scene, damaged property, or your injuries.
  • Bring us your auto insurance policies. (You might have a separate policy called an “Umbrella Policy” which also has auto insurance coverage in addition to that which your car insurance policy has.) Unless special, separate arrangements are made with you, we will not be handling your private insurance benefits collection for you, but we should know what insurance may be involved in the matter.
  • Keep all personal property which was damaged in the accident. This even includes clothes that were ripped and torn beyond repair in the accident.
  • Bring us any proof of your property damage. Proof means things like the item itself, or a photo of it, all repair bills, and all repair estimates. Because we have to prove that you owned the item and how much it was worth before the accident, bring in any proof of purchase price, and proof of ownership (including the certificate of title, purchase invoices, or bills of sale).
  • Bring us any statements you have given about the accident. As soon as possible, bring us any written statements made by you to anyone (police, insurance adjuster, the other driver, your employer, and so on). If you remember making a statement but do not have a copy to bring us, make a note to tell us about it, so we can use an authorization from you for us to get it if we need it.
  • Bring us any correspondence to and from insurance adjusters (including a printout of any emails) and any business cards of insurance adjusters that may have been provided to you.
  • Keep a separate medical trips list. List the date of each trip to a doctor, hospital, therapy session, pharmacy, or any other place for medical care or supplies. Just use a few sheets of paper and write it down. Write down the date, where you went, and what your trip was for (examples: “Dr. Smith for three month checkup,” or “Safeway Pharmacy for bandages and prescription pickup,” or “Arizona Spine for PT”). Bring this medical trips list in with you the next time you see us. We probably will show that medical trips list to the other side as a part of our settlement attempts, or maybe even use it if we get to trial, to show the jury all the trouble you have. Keep the list clear of extra items (list should be only the date, the place you went to, and the medical care or supplies the trip was for).
  • Keep a separate medical expense list. Just use a few sheets of paper and write it down each day you have a medical expense. List each one of your medical expenses and out of pocket expenses (e.g., Dr. Smith’s bill, pain killers, heating rubs, bandages). We can’t ask for the other side to pay expenses that you do not tell us about.
  • Keep a separate daily list of how your life is affected as a result of the accident. List things such as what you cannot do now, things you find you are not able to do as well now as you did before the injury; things you can do but it hurts. Describe how your day went with regard to the presence or absence of pain or embarrassing incidents that happened because of your injuries. Make each entry short and to the point. We may want to show this list to the other side, so put down something each day your life is affected. Remember, this list may be shown to the other side, so make any other notes to discuss with us on a separate piece of paper.
  • Bring all three lists with you every time you come to the office to see us. We will make a photocopy for our use and then give it back to you to add to it until you see us next time.
  • Keep any medical appliances and items that doctors prescribe or have you use. We need them as possible exhibits (including all braces and supports, crutches, prostheses, etc.). Things the doctors prescribe for you that you should save include all empty pill bottles. Sometimes a pile of pill bottles works better than words on a settlement table. If you throw them away, we won’t be able to consider using them as exhibits to make people really think about your pain.
  • Report any suspicious activities to this office. You may be under surveillance by investigators. Movies, videotapes and still photographs may be made of you. Be mindful of your actions!
  • E-mails – Be aware that anything you have on a computer can be discovered and read by the other side. Copies of your emails are stored many places on the Internet as they are sent to and from the persons involved, and it is impossible to “delete” an email so no one will ever see it. It’s quite possible that you may receive email or send email that mentions the accident. Be mindful of your emails, and tell us about any that have involved the accident.
  • Bring us a copy of your last year’s tax return.
  • Bring us things that show your earnings before and after the accident. (For example, payroll check stubs or wage statements.)
  • In wrongful death cases we need the following regarding the deceased: marriage licenses, birth certificates, adoption orders, probate or guardianship documents, photographs and videotapes of the deceased, divorce and/or annulment papers, funeral expenses, any biographies or lists of accomplishments of the deceased, and diplomas obtained by the deceased.

Remember: We are working hard to recover what you are due. The things you bring in to us are only a part of the total information we will be assembling on your behalf, but it’s a good way for us to start. The more you tell us about expenses and how your life has changed since the accident, the better job we can do for you.