- State your name and address or principal place of business, date of birth and social security number.
- Have you been convicted of a felony? ______If so, for each felony state:
- The original charge made against you.
- The charge of which you were convicted.
- Did you plead guilty of the charge or were you convicted after trial?
- The court and cause number.
- Were you plaintiff or defendant?
- What was the nature of the plaintiff’s claim?
- When, where, and in what court was the action commenced?
- State the names of all the parties other than yourself.
- The name, address, and occupation of the person or organization conducting the investigation.
- The date or dates on which the investigation was conducted.
- Whether you or anyone acting on your behalf has interviewed or spoken with any other party or any of its agents or employees about the event in question. ______If so, please identify the individual spoken with and the substance of the conversation.
- The name and address of the person now having custody of any written report made concerning the investigation.
- The name and address of each person.
- The field or science in which each such person is sufficiently skilled to enable opinion evidence in this action.
- Whether such potential witness will base his or her opinion:
(1) In whole or in part upon facts acquired personally by him or her in the course of an investigation or examination of any of the issues of this case, or
(2) Solely upon information as to facts provided him or her by others. - If your answer to 7(C) discloses that any such witness has made a personal investigation or examination relating to any of the issues of this case, state the nature and dates of such investigation or examination.
- Each and every fact, and each and every document, item, photograph or other tangible object supplied or made available to such person.
- The general subject upon which each such person may express an opinion.
- Whether such persons have rendered written reports. ______If so:
(1) Give the dates of each report.
(2) State the name and address of the custodian of such reports.
- Describe in detail all injuries, whether physical, mental or emotional, experienced since the occurrence and claimed to have been caused, aggravated, or otherwise contributed to by it.
- For all injuries mentioned in the proceeding interrogatory, please identify those injuries which are considered by you to be permanent.
- As to each medical practitioner who has examined or treated any of the persons named in your answer to Interrogatory No. 1 above, for any of the injuries or symptoms described, state:
- The name, address and specialty of each medical practitioner.
- The date of each examination or treatment.
- The physical, mental, or emotional condition for which each examination or treatment was performed.
- The name and address of the person or organization paid or owed for the medical expense.
- The amount.
- The date of each item of expense (attach copies of the itemized bills, if desired).
- The person or organization who paid the medical expense.
- The condition for which you incurred the expenses.
- Will you incur medical expenses in the future as a result of the accident in question? ______If so, state the amount of medical expenses which will be incurred in the future and state in detail the knowledge and source upon which you rely in support of this belief.
- The specific condition which you claim caused the loss of time.
- The amount of time lost.
- The rate of pay or compensation regularly received from each such gainful employment.
- If you claim any damage as a result of the time lost, the total and your method of computation.
- Name and address of employment.
- Date of commencement of and date of termination.
- Place of employment.
- Nature of employment and duties performed.
- Name and address of immediate supervisor.
- Rate of pay or compensation received.
- The specific condition which limits your ability to engage in gainful employment.
- The economic loss caused by your inability to find gainful employment.
- Your method of computation for computing such loss.
- The name of the company or companies, including any excess or umbrella carriers, which you claim provide coverage.
- The policy number or numbers of any applicable policy.
- The limit or limits of liability of each policy.
- The named insured on each policy.
- Whether the insurance carrier has accepted or denied coverage.
- Whether you are being defended by the insurance carrier under a reservation of rights.
- Did the vehicle which you were occupying at the time of the accident contain operational seatbelts? _____ If so, were you wearing seatbelts available for your use? _____
DATED this ____ day of _____________, _____.
Attorney for Plaintiff
ORIGINAL of the foregoing mailed this
____ day of ___________ 20__, to:
Attorney for Defendant
Arizona Personal Injury Complaints
Arizona Interpleader Actions
Arizona Discovery Documents
Arizona Pre-Litigation Documents
Disclaimer: The information and forms on this site are for illustrative purposes only. The information is not intended to be used by anyone other than a licensed Arizona attorney familiar with Arizona personal injury law. The forms and the information contained in them may not be up-to-date and must be independently reviewed, cite checked, rule checked, and otherwise verified by a licensed Arizona attorney. The information contained in the forms on this website cannot and must be relied on for the purposes of filing legal documents or otherwise pursuing a claim. If you have any questions about this, please contract and attorney at LamberGoodnow.com or by calling 602-833-1274.
Locations
Phoenix, Arizona
602-ARIZONA (602-497-4861)
2394 E Camelback Rd #600
Phoenix, AZ 85016Denver, Colorado
303-800-8888
1700 Lincoln Street #2400
Denver, CO 80203Chicago, Illinois
312-757-7777
141 West Jackson Boulevard #4219
Chicago, IL 60604Tucson, Arizona
520-477-7777
1 S Church Ave #1000
Tucson, AZ 85710Nogales, Arizona
520-394-4733
420 West Mariposa Road, Suite 200
Nogales, AZ 85621Las Vegas, Nevada
702-625-7777
300 S. 4th Street #1400
Las Vegas, NV 89101Reno, Nevada
775-386-6155
300 E. 2nd Street
Reno, NV 89501Lamber Goodnow Injury Lawyers
© 2022 by Lamber Goodnow Injury LawyersTM. All rights reserved. A division of Fennemore.
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M. Lamber is licensed in Arizona, Colorado, Illinois and New York only. G. Goodnow is licensed in Arizona, Colorado, Illinois, New York and Washington D.C. (inactive) only. Matters outside of these jurisdictions are handled by Fennemore Craig, P.C., lawyers licensed in the relevant jurisdiction or by or with the assistance of attorneys at other associated, co-counsel law firms who are licensed in the relevant jurisdiction.
* Chris Goodnow and Justin McKay, lawyers licensed in Arizona, are partners with and owner of the outside law firm of Goodnow McKay. He is not an employee or director of Fennemore Craig, P.C., or Lamber Goodnow, which is a division of Fennemore Craig, P.C. Instead, with written client consent, Goodnow McKay is a co-counsel law firm with which Lamber Goodnow associates on cases.
*IMPORTANT – READ CAREFULLY: Past results do not guarantee, warrant, or predict future case outcomes. Every case involves risk, including the risk of loss. Results turn on, among other things, the facts and law applicable to each unique case. You may have to pay the opposing party’s attorney fees and costs in the event of a loss. Lamber Goodnow Injury LawyersTM is a division of Fennemore Craig, P.C.
Read more here.
Disclaimer
Historic Success Rate and Results Not Predictive and Results Not Guaranteed
Past results, including verdicts and settlements, are not indicative or predictive of future results or outcomes. Every case is different, and case results turn on the unique facts, circumstances, and applicable law involved in a given matter. Every case involves risk, including the risk of loss.
Historic “success rate” (i.e., percentage of cases settled or won) is for informational purposes only. Past results and/or success rates are based on cases handled by personal injury group attorneys that have resulted in either (a) settlement (regardless of amount) or (b) trial/arbitration in favor of their clients. Matters in which either client or attorney terminated representation prior to the conclusion of the matter are excluded from this analysis. Under no circumstances can historical success rates, settlement rates, trial win rates, or any other historical data be used as an indication of what may happen in your case. The amount of a settlement is not a factor in this analysis or in the definition of “success.” Additionally, the amount of any healthcare provider liens and/or health insurance reimbursement/subrogation claims — and any reduction of these, if any, secured by the firm — is not included in the definition of “success.” You may have to pay the opposing party’s attorney fees and costs in the event of a loss.
We engaged an outside economic consulting firm to calculate our success rate. To learn more about the methodology used by the economic firm, you may read its full report by clicking here.
There are never any guarantees about case outcomes. It is possible that any case can end in a loss regardless of what has happened in other cases in the past.
Cases Handled by Different Lawyers, including Lawyers Licensed in Relevant Jurisdiction
Cases may not be handled by M. Lamber or G. Goodnow; instead, other lawyers within the firm may be assigned to handle the matter, or with client consent the firm may associate with attorneys at outside law firms to handle the matter.
Cases are managed and handled by attorneys in the relevant jurisdiction. Marc Howard Lamber (“Marc Lamber”) is licensed to practice law in Arizona, Colorado Illinois and New York only. Gordon J. Goodnow III is licensed to practice law in Arizona, Colorado, Illinois, New York, and the District of Columbia (inactive) only. Matters outside of these jurisdictions are handled by firm attorneys licensed in the relevant jurisdiction or by attorneys at associated law firms licensed in the relevant jurisdiction.
Contingent Fee and Costs
In personal injury cases, we operate on a contingent fee. This means that our fee is a percentage of any recovery we obtain for you, whether by settlement or verdict. Clients are not responsible for paying us fees or costs if we do not recover. This does not include any of the defending party’s fees or costs that a court/arbitrator may assess against a client (e.g., in the event a case is not successful).
In the event of recovery, all case-related costs and expenses will be advanced by the firm or firms handling the matter, but the client agrees that these costs will ultimately be paid from client’s share of the recovery. Client has no obligation to front these expenses or to pay out-of-pocket for these expenses during the pendency of the case. If there is a financial recovery, however, the client agrees that the firm or firms will be reimbursed for these expenses out of the recovery; if there is no financial recovery, our firm will write off the expenses and the client will not be charged for them. Examples of costs and expenses include but are not limited to amounts paid to third parties not employed by our firm, costs of medical records, private investigators, expert witness fees and costs, shipping charges, messenger costs related to the execution of this agreement, electronic research charges, and other expenses borne by the handling law firm(s). If a lawsuit is filed and the defending party prevails, a court may assess the defending parties’ attorneys’ fees and/or taxable costs against the client.
Association/Co-Counsel with Outside Firms May Take Place
We may associate or co-counsel on certain matters with lawyers not in our firm. When this occurs, there is generally no additional fee for involving another law firm or lawyer; more specifically, the contingent fee percentage generally remains the same (if not, this would be disclosed the client and require an addendum to the controlling attorney-client agreement). In this situation, the associating attorney may serve as lead counsel on the matter. In the event a matter is associated, fees will be shared between Fennemore Craig P.C. and the associated law firm in an amount disclosed to the client in the attorney-client agreement or by another writing. As required by controlling ethics rules, Fennemore Craig P.C. and the associating law firm will remain jointly responsible for the matter. Even when a matter is associated and the co-counsel firm is serving as lead counsel, clients may always contact Fennemore Craig P.C. to inquire about the status of their matter.
This Web Site is Not Legal Advice
The information contained in this web site has been prepared for informational purposes only and is not legal advice. It is provided only as general information which may or may not reflect the most current legal developments. This information is not provided in the course of, and receipt of it does not constitute, an attorney-client relationship, and it does not substitute for obtaining legal advice from an attorney licensed in your state. Legal advice should take into account the specific facts of your situation, and you should not draw any particular conclusions from the information presented here. You should seek professional legal counsel before acting upon any of the information contained in this web site. Before sending information to us, however, please speak with one of our lawyers and get authorization to send that information to us.
No Attorney-Client Relationship Created
No attorney-client relationship is created by viewing this site. While we would like to hear from you, we cannot represent you until we know that doing so will not create a conflict of interest. Accordingly, please do not send us any information about any matter that may involve you until you receive a written statement from us that we represent you (an “engagement letter”). Similarly, no attorney-client relationship is created if you send us email. The best way for you to initiate a possible representation is to call one of our lawyers. He/she will first take you through our conflict of interest procedure and see that you are put in touch with the lawyer best suited to handle your matter. When you receive an engagement letter from the lawyer, you will be our client, and we may exchange information freely.
Any information provided to us before we have conducted a check for conflicts of interest and before we have agreed to represent you, is not subject to the attorney-client privilege or otherwise confidential and accordingly may be used by us for any purpose.
The use of Internet email for confidential or sensitive information, however, is discouraged, and we request that you first discuss with us by telephone the nature of the information you plan to send by this medium.
State Laws and General Information on Site
This website contains information about general or common rules that apply in some states. This web site also contains information about verdicts or settlements in past cases. You cannot assume that the same rules apply, or that the same result would occur, in your state or any particular state.
Blogs, Podcasts, Multimedia Issues
The materials on this site are prepared by Fennemore Craig. This site is a purely public resource of general information that is intended, but not guaranteed, to be correct and complete. It is not intended to be a source of solicitation or legal advice. Postings are not solicitations or legal advice and are for informational purposes only. This information is not intended to create and receipt of it does not constitute an attorney-client relationship. The reader should not rely or act upon any information in this site without seeking professional legal counsel. If you wish for Fennemore Craig to consider representing you, please contact the firm directly.
The authors of this site are licensed in the States of Arizona, Nevada and Colorado. The authors provide and will provide links to other websites for lawyers and other law sources related to various topics, but the authors do not intend such links to be referrals for employment. Further, the authors cannot vouch for the truth or accuracy of those sites. The authors do not wish to represent anyone who viewed this site in a state where the site fails to comply with all laws and ethical rules of that state.
The authors grant permissions to readers to link to this site so long as this site is not misrepresented. The authors will remove any link to any site from this site upon request of the linked entity. This site is not sponsored or associated with any other site unless so identified.
Circular 230 Client Explanation
On June 21, 2005, final regulations commonly known as “Circular 230″ became effective. Circular 230 was issued by the United States Department of Treasury. It sets forth detailed rules that tax practitioners (including attorneys and accountants) must follow when providing written communications regarding certain Federal tax issues. A “Federal tax issue” is a question concerning the Federal tax treatment of an item of income, gain, loss, deduction or credit, the existence or absence of a taxable transfer of property (such as whether a transfer to another is subject to Federal gift tax) or the value of property for Federal tax purposes.
When it issued Circular 230, the Department of Treasury articulated its objective to “restore, promote and maintain the public’s confidence in those individuals and firms” that provide tax advice. The failure by a tax practitioner to comply with the requirements of Circular 230 may result in severe penalties, including public censure, monetary fines and/or suspension or disbarment from practicing before the IRS. One nationally prominent tax practitioner and author makes the following observation regarding Circular 230:
[The Regulations] are any attempt by the Service to balance concerns about overly aggressive advice provided by some practitioners who were involved in the promotion of abusive tax shelters on the one hand, and the potential imposition of burdensome requirements on the great majority of tax practitioners who never issued such opinions. In that light, the final Regulations can be viewed as a compromise, but one that leans more towards enforcement. Once again, the many will pay for the sins of a few.
Circular 230 applies to not only formal legal opinions but also any writing relating to any Federal tax matter, including e-mail communications. In particular, tax practitioners must now comply with a number of detailed requirements when providing a “Covered Opinion,” including the following:
(i) the practitioner must make reasonable efforts to identify and ascertain all relevant facts and may not base the opinion on any “unreasonable factual assumption”;
(ii) the practitioner must relate the applicable law – including “any potentially applicable judicial doctrine” – to the relevant facts;
(iii) with very limited exceptions, the opinion must consider all “significant” Federal tax issues and reach a conclusion as to the likelihood that the taxpayer will prevail on the merits on each such issue (or if a conclusion cannot be reached, the opinion must so state);
(iv) the practitioner must reach an “overall conclusion” as to the likelihood that the stated Federal tax treatment of the arrangement or transaction is the proper treatment and set forth the reasons for that conclusion; and
(v) if any one of a number of conditions apply to the opinion, the practitioner must “prominently disclose” those conditions.
There are several categories of “Covered Opinions” which are generally not applicable to the tax practice currently maintained by Fennemore Craig. However, the definition of a Covered Opinion is very broad and generally includes any written communication (including e-mail) that (i) addresses a Federal tax issue, (ii) reaches a conclusion favorable to the taxpayer at any confidence level, and (iii) is intended to be relied upon by the taxpayer to avoid penalties.
Unfortunately, this firm (and many other firms and individual tax practitioners) anticipate that Circular 230 will increase the cost of delivering to clients written materials discussing tax issues. In most day-to-day correspondence – especially e-mail communications – the costs of complying with the requirements imposed by Circular 230 are likely to be prohibitive relative to the benefit of the written tax advice.
Tax practitioners can provide certain types of written communication on tax issues without complying with the extensive requirements of Circular 230 if the written communication includes a statement that the advice given may not be relied upon by the taxpayer to avoid penalties. Consequently, after June 20, 2005, clients of Fennemore Craig will see certain “reliance disclaimers” in various communications from the firm, including e-mail messages. It is anticipated that most written communications from Fennemore Craig attorneys that address Federal tax issues will also include the “reliance disclaimer” unless there is an agreement between the firm and the applicable client as to the need for an opinion that satisfies the requirements of Circular 230.
It is our intention to endeavor to continue providing the highest quality legal services to our clients in a cost-effective manner. Please call us if you have any question about how Circular 230 may affect our representation of you in connection with Federal tax matters.
Copyright Notice
©2016 Fennemore Craig, P.C. Fennemore Craig is the owner of the copyright in this web site. You may not copy, download, store, transmit, or otherwise make electronic or paper copies of this site, or any portion thereof, without express permission of Fennemore Craig. Permission is freely granted for most requests. All other rights reserved.
For questions email: info@lambergoodnow.com
“Lamber Goodnow” is a Division of Fennemore Craig, P.C.
The “Lamber Goodnow Injury Law Team at Fennemore Craig, P.C.” consists of attorneys, including M. Lamber and G. Goodnow, who are directors and/or employees of Fennemore Craig, P.C.; there is no separate “Lamber Goodnow” law firm or business entity.
“AV” and “BV” are Certified Marks of Reed Elsevier
AV Preeminent and BV Distinguished are certification marks of Reed Elsevier Properties Inc., used in accordance with the Martindale-Hubbell certification procedures, standards and policies. Martindale-Hubbell is the facilitator of a peer review rating process. Ratings reflect the confidential opinions of members of the bar and the judiciary. Martindale-Hubbell ratings fall into two categories: legal ability and general ethical standards.
