Every case is different, but an experienced Chicago personal injury lawyer does the following things in almost every third party liability suit that goes to trial:
• Investigate the accident• File suit and serve the defendants with suit papers• Files responses to motions to transfer venue• Analyzes and responds to affirmative defenses• Prepares and answers written discovery• Obtains photographic evidence of injuries where needed• Files motions to compel• Analyzes the contribution case and insurance coverage issues• Presents the plaintiff for deposition• Takes multiple depositions • Meets with witnesses• Analyzes the contribution case and insurance coverage issues• Responds to pre-trial motions to dismiss and for summary judgment• Obtains and analyzes medical records• Doctor depositions• Coordinates third party liability suit with worker’s compensation case• Analyzes case for settlement potential• Engages in settlement negotiations and/or mediation• Selects and hires well-qualified liability, medical, and/or damages experts• Identifies and discloses trial witnesses for all aspects of trial• Presents experts for deposition• Reviews defendant trial witness disclosures• Takes depositions of defendant expert witnesses• Selects and prepares trial exhibits• Conducts pretrial focus groups• Prepares all cooperative witnesses for testifying• Prepares for questioning all other witnesses• Prepares pretrial evidentiary motions and researches anticipated defense motions• Issues notices to appear and subpoenas for trial witnesses• Prepares jury instructions• Prepares questions for jury selection• Prepares opening statements and closing and rebuttal arguments• Argues pretrial evidentiary motions• Conducts jury selection• Gives opening statement• Puts on case in chief• Responds to defense case in chief• Offers rebuttal evidence• Participates in a jury instruction conference• Gives closing argument and rebuttal argument• Prepares judgment order based on jury verdict• Prepares and/or responds to post-trial motions• Handles appeals to Appellate Court and/or Illinois Supreme Court, if needed• Enforces judgment• Disputes questionable claimed liens• Verifies the correct amount of liens• Disburses money to client and lienholder as required• Provides full accounting of all money from verdict or settlement to the client
