Law 421 Week 1 Memo Sample

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Good afternoon Amy, I took the applicant's deposition on Wednesday, October 14, 2015, in the applicant's attorney’s office. The applicant’s attorney did not have a demand. He stated that the applicant was more interested in “getting better”. The applicant’s attorney stated that he would like to get this case moving and suggested that we go to an Agreed Medical Examiner. He recommended Drs. Gleiberman, Halbridge, and Suzuki. I would not recommend the use of an Agreed Medical Examiner. It does not appear that we will be able to settle this case without going to an independent doctor. I would recommend a panel qualified medical examination after the next deposition. At the beginning of the deposition I had three main goals: 1. Determine the reason that the date of injury had changed. 2. Find out about the applicant playing soccer. 3. Determine if there was another activity that the applicant participated in that could have caused the injury. I am pleased to say that I did determine the answers to these questions. …show more content…

De Carlo. His last appointment was 9/29/15. I do not have this report. According to the applicant, the doctor changed his modified duties from not being able to lift 10 pounds and no prolonged sitting to no lifting more than 20 pounds. I will verify this once I have the report. His doctor recommended the applicant to have acupuncture and physical therapy. He said that there has not been any discussion of surgeries or injections. He takes Naprosyn three times a week. He claims that he began having radiating pain into his knee since he started treating at Southland Spine. He claims this pain occurs three times per month. He is also receiving chiropractic care and medication which he claims is beneficial. The applicant did have an x-ray of his back. He claimed that the doctor told him his back was not aligned properly. He has not told his treating doctors that he helps his father on a daily