In personal injury cases, defense lawyers typically prepare a medical chronology, which summarizes the Plaintiff’s medical treatment in chronological fashion. This helps defense lawyers understand various important facts: how the Plaintiff’s treatment progressed, whether the complaints of injury were consistent over time, and other medical issues. But medical records are not the only source of information. We seek out employment records, family court files, and other relevant, non-medical sources of information. So why are these not typically included in the chronology?
Take, for a hypothetical example, a Plaintiff who alleges that he suffered a traumatic brain injury, which led to seizures several months later. The medical chronology tells you that the Plaintiff sought medical treatment for head injury and that he subsequently endured seizures. So, on its face, the TBI/seizure claim seems legitimate.
But what happens when you incorporate the worker’s compensation file and the family court file?
You find out that the plaintiff was found to be at MMI on March 1 following the January 1 accident, and that he was subsequently cleared to return to work. You find out that his spouse filed for divorce alleging drug and alcohol abuse on March 3, including that he used twice the recommended dosage of prescription anxiety medicine every day and mixed it with high levels of alcohol. You also learn that the Court set a hearing to temporarily work out the child custody issue on March 8. So, the March 7 seizure, which initially appeared to be a delayed effect of TBI, now appears to be related to mixing alcohol with prescription drugs and/or withdrawals caused by quitting prescription pain medication cold turkey in order to present well at the family court hearing.
The point of this is, if you are not doing so already, you should incorporate all of the documents you receive into a master chronology that provides the entire picture.