May 23, 2023


Attorney Work Product

  Date/Time   Source   Facts   Notes
  [Enter the date and time of the event forming the basis of the Complaint and/or investigation.   If you cannot remember the exact date, try to put down the month and year. If you are not sure what month something happened, try to identify whether it happened before or after some other incident in the chronology.]   [Enter the source of the information that you intend to use for the report. These may include nursing records, treatment notes, and consent forms.   Also include a list of witnesses, both favorable and unfavorable. Please include each witnesses’ address, telephone numbers, and a summary of the knowledge of those witnesses.]   [Enter an outline of the facts that form the basis of the Complaint and/or investigation. Be keen to include every detail that may be essential to the elements of the allegations and/or causes of action.   Be as detailed as possible about the events which are the reason for the lawsuit.   Identify people by their full names whenever possible, and include their job titles if possible.]   [Make notes on your interpretation and/or application of the facts to any applicable law. Also comment on whether the evidence obtained from the records and/or sources will suffice the arguments you intend to set forth in the case]

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