Review billing and insurance records.

When conducting discovery of a client's medical treatment in a personal injury case, be sure to obtain his or her billing and insurance records. They can serve as a road map for discovery.

These records detail the procedures the client has undergone and define any special damages, as well as the collateral-source payments for damages. Billing and insurance records may also reveal physicians, not otherwise identified in the medical records, who may have relevant information. Insurance billing statements for years preceding the subject incident may identify preexisting injuries and detail their treatment.

Gayle M. Blatt

San Diego, California 

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