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Warren Schneider
Marjory Harris


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It may be a scribbled note, hard to
decipher, or a lab order form. If you
scan quickly, it may not leap out.


I first began workers’ compensation practice as a
defense attorney. A huge file was delivered to
my office, with subpoenaed records from the
workers' compensation case and third-party
case. I began plowing through the records,
starting with the pleadings, then the transcripts
of the plaintiff's deposition, and finally the many volumes of subpoenaed medical records.
The injured worker was claiming orthopedic,
neurologic, and psychiatric injuries from a fall.
He claimed he had been rendered impotent and
celibate since the accident. Imagine my joy when
I found, buried in the voluminous records of a
hospital, a lab slip dated well after the accident.
It accompanied a specimen that was to be
checked for gonococcus. Hand written on the
slip, "Admits to two coital partners." The various
attorneys defending the third parties had not
found this, having better things to do with their time than read the lab slips in bulky records.

Next >
Smoking Gun
By Marjory Harris

Look for some good tips from WC attorneys
as they tell their war stories in this monthly feature
> Write the Right request
> Sample Requests
> Psychiatric Records & Releases
> Interview with Mervin Glow
> Organizing Your Work with Excel
> Smoking Gun
Look for parallel entries,
especially in hospital
records, where nurses’
notes are separate from
doctors’ orders. Read lab
forms carefully – they
may contain gold nuggets.