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With regard to medical records, in


those cases where your client has a complex and extensive medical history, consider providing the Defendant (or an insurance adjuster) with a specific authorization signed by your client to obtain those records, in exchange for an agreement that they will provide you with a free copy of every record they ob- tain. This can save your client hundreds of dollars, and opposing counsel will almost always agree to this. If you obtain a large volume of medi-


cal records, and provide a copy of those records to the defense attorney, it is reasonable to request reimbursement for photocopying. Furthermore, color copies can be expensive. It is therefore reasonable to request that defense coun- sel agree to reimburse you for the cost of duplicating photographs and other such documents.


Deposition Transcripts Deposition transcripts are amongst


the largest expenses in litigation. In smaller automobile cases, consider whether you truly need to take the defendant’s deposition. Well-crafted discovery utilized early in discovery, can in some cases, be used to force a stipulation on liability, thereby negating any need to depose the defendant and liability-fact witnesses. Also, consider holding off on purchasing a copy of your client’s deposition until you are certain that the case will go to trial.


Utilize the Resources That MTLA Provides


MTLA provides its regular members


with many benefits that help minimize costs. For example, the MTLA Website has an online-document repository which can be easily accessed by plain- tiff ’s attorneys at minimal cost, and it contains a wealth of useful information, including sample motions, complaints, interrogatories and other litigation documents.11


Reinventing the wheel is 11 www.mdtriallawyers.com Summer 2008 Trial Reporter 35


a waste of time when tried-and-true forms are available and searchable at your fingertips. MTLA also has a Defense Expert Da-


tabase and a Deposition Library. These databases provide information that is crucial for effective cross examination of defense experts at trial. Using these tools can often alleviate the need to de- pose a defense expert witness. Similarly, the MTLA Listserve, and networking with the MTLA Auto Negligence Sec- tion, are also fantastic resources for obtaining advice from experienced trial lawyers. Consider consulting members of the Listserve or of the Auto Negligence Section with complicated legal-research questions prior to spending money and time re-inventing the wheel.


* * * * In summary, a cost-effective approach


to auto-tort litigation can effectively yield an increased recovery for your client. While each particular case will require a careful analysis of its own particular facts, budget and the elements required for proof, the above strategies should be useful to any new or solo practitioner in litigating automobile-accident cases in a cost-effective manner. n


About the Author


Mark A. Schofield is an associate with Goldberg, Finnegan & Mester, LLC. He is a graduate of Wesleyan University and the College of William and Mary School of Law. He is admitted to practice in Maryland, Virginia and the District of Columbia. His practice focuses on personal injury matters.


Justin Katz graduated from The Catho- lic University Columbus School of Law in 2003 and from Washington University in St. Louis in 2000. Since that time he has been actively practicing as an asso- ciate attorney at Goldberg, Finnegan & Mester, LLC where he litigates automo- bile accident and premises liability cases in the District Courts and Circuit Courts throughout the State of Maryland. Mr. Katz recently obtained a large verdict from a Prince George’s County jury on behalf of a lady who slipped and fell on a dangerous ceramic tile surface. Mr. Katz is a member of the Maryland Trial Lawyers Association (MTLA), and is actively involved in the MTLA Automo- bile Negligence Section. Mr Katz can be reached at jkatz@gfmlawllc.com.


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