AI Analysis:
The user's real question is a keyword search for 'injury.' This message directly involves a personal injury matter — specifically, a 6-year-old minor client who 'suffered emotional distress and physical injuries in a car accident.' The message is from a personal injury attorney discussing a case involving injuries. However, the message is primarily a question about procedural privacy concerns (filing a Minor's Compromise under a Doe name and redacting medical records), not a substantive discussion or answer about the nature of the injuries themselves. It mentions injury in a meaningful, substantive context rather than merely in passing, but the core content is about court filing procedures rather than injury law or injury analysis. It qualifies as relevant to the keyword 'injury' at a moderate confidence level given the direct reference to physical injuries in a legal context.
"Nancy Cole Loeterman" Date: August 11, 2026 1:12:00 PM Subject: Minor's compromise - can it be filed under Joe Doe? Name redacted in attachments? Reply to list Reply to sender Print Attachments: winmail.dat (17 K) List: caala-workproduct Sent by: Nancy Cole Loeterman (Reply Privately) Search My 6 year-old minor client has autism and suffered emotional distress and physical injuries in a car accident. Child's parents are high net worth. They're concerned about public nature of Petition for a Minor's Compromise and attachments, since documents will necessarily refer to medical records that discuss the psychological impact of the accident with the autism overlay. Is it possible to file a Minor's Compromise with: 1) child as a Doe; and 2) parents as Does? Also, to redact child's name in the medical records attached to the Petition? Thanks very much. Nancy Mobile: 310-266-4643 Nancy Cole Loeterman Personal Injury Law Cole & Loeterman 1801 Century Park East, Suite 2500 Los Angeles, CA 90067 Office: 310-556-8300 ext. 2 Fax: 310-772-0807 https://www.linkedin.com/in/nancy-cole-loeterman-833704b/ This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged information. If you are not the intended recipient: Any use, copying, disclosure, dissemination or distribution is strictly prohibited; and, please so notify the sender immediately by return e-mail, delete this communication and destroy all copies.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message directly involves an injury — a 64-year-old client who suffered a slip-and-fall at a Peet's Coffee patio, resulting in knee abrasion/bruising, hand discoloration, and ongoing knee, hip, and back pain. The message describes the nature, circumstances, and current status of the injury in some detail. While this is a premises liability referral post rather than a workers' compensation discussion, it does substantively describe an injury incident and its physical consequences, which is directly responsive to a broad keyword search for 'injury.' However, it is a referral solicitation rather than a legal analysis or discussion of injury-related legal principles, which limits its depth of relevance.
"Emma Samyan" Date: August 11, 2026 10:27:00 AM Subject: Peet's Coffee - Potential Premises Liability Referral Reply to list Reply to sender Print List: caala-workproduct Sent by: Emma Samyan (Reply Privately) Search Looking to refer a potential slip-and-fall/premises case arising from a 7/18/26 incident at an outdoor coffee-shop patio in Santa Clarita. Client fell while descending a two-step curved concrete elevation change. Steps appear to have no contrasting edge markings or handrail, and the patio/steps are the same or very similar concrete color/material. Client is 64 and treated at urgent care immediately afterward, where X-rays were taken. No fractures or other significant injuries have been identified to date, but she had a visible knee abrasion/bruising and hand discoloration and continues to report knee, new hip, and back pain. I have scene and injury photographs available. Property/common area appears to be managed separately from the coffee shop. Please email me if interested in reviewing for potential referral.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message substantially involves injury — specifically, a 76-year-old plaintiff who suffered a traumatic brain injury (TBI) and post-traumatic daily headaches/occipital neuralgia after falling down stairs at an RV park. The message describes the nature of the injury, the physical decline of the plaintiff, and references a $5.975M verdict. While the message is primarily a verdict announcement and congratulatory discussion rather than a legal analysis of injury law or doctrine, it does contain substantive information about the nature and consequences of a personal injury, making it meaningfully relevant to a search for content involving 'injury.'
"Marilyn Listserve" Date: August 09, 2026 3:06:00 PM Subject: Re: Verdict in San Luis Obispo! Reply to list Reply to sender Print List: caala-workproduct Sent by: Marilyn Smith (Reply Privately) Search Incredible result, congratulations! Another example of how risky it is to flat out claim someone is lying – better have unimpeachable receipts to prove it. What was plaintiff’s last demand? Were there any 998s so you get your expert costs? Marilyn M. Smith Marilyn Smith Law APC 301 E. Colorado Blvd., Suite 620 Pasadena, CA 91101 V: 626-683-8102 www.marilynsmithlaw.com This email does not constitute particularlized legal advice and is intended for informational or work product discussion purposes within a closed listserve. It is not to be distributed outside of the CAALA Listserve. This email address is used only for Listserve purposes. To contact me directly, please send an email to Marilyn@Loomms.com . From: Srinivas Hanumadass (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Sunday, August 9, 2026 9:17 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Verdict in San Luis Obispo! List: caala-workproduct Sent by: Srinivas Hanumadass (Reply Privately) Search Happy to report a $5,950,000 from my partner Domenic Martini and Ben Koh. Both are not just future stars anymore. They arrived. See Dom's write up below: Good Evening: Happy to report that Ben Koh and I got a $5.975M verdict in Paso Robles, San Luis Obispo Superior Court yesterday. Here's our write up: Facts: 76 year old Mark Nickerson was walking down some stairs in a cabin at an RV park when one of the stairs slid backward off its tracks and sent him falling to the ground. He struck his head and lost consciousness. Screenshot 2026-08-06 at 8.37.45 PM.png Mark suffered a TBI and post-traumatic daily headaches that had characteristics of occipital neuralgia. He declined physically - going from riding Harleys at 76 to needing a walker at 78 (at the time of trial). He underwent about every kind of injection, from botox to ESI to RF ablations and nerve blocks. Trial: Ben and I jumped into this case at the TRC and were brought in by fellow CASD member Andrew Zucker. Shoutout to Andy, who did a fantastic job getting this file teed up for us to come in and take a swing! Defendant's last and best offer was $750,000. Judge Michael Kelley presided over the trial. He bifurcated the trial over our objection but I think in the long run he did us a huge favor. During Phase 1 - We proved the defendant owned the cabin for 9 years and had identical models on their property. On two prior occasions, steps had come loose in other unites and needed to be replaced. After those occasions, defendant did not stop to inspect all the units. The defendant kept no maintenance records and performed no routine inspections. They basically relied on housekeepers to report issues. Defendant had two main points: (1) that our client lied about how this happened and instead just fell down the stairs; and (2) that these cabins are manufactured products and thus this was a products case. Ask me about all the ways they tried to say our client was lying when you see me next. It's too much for this post. But they trotted out two employees who supposedly saw the step in perfect condition while he was being treated by EMTs. We had time stamped photos to disprove their testimony. We got to hit them with their bad incident report and the fact that the employee who "fixed" the step had no memory at all of what it looked like despite remembering the two OSIs with perfect memory. The jury returned a phase 1 verdict of 82.5% liability on the defendant, 17.5% liability on the manufacturer (who was an empty chair defendant) and 0% on our client. We won 10-2. I definitely had some anxiety about the empty chair manufacturer, but my argument that the jury appreciated was that after 9 years, every product breaks down and needs maintenance. Still, they thought the original manufactured screws were too short. Brad Avrit was our expert and while I thought he testified very well, he had an early report that the defense got to use to blame the manufacturer. Phase 2 was fun, because we knew 10 jurors liked us and 2 didn't. That was the beauty of bifurcation. We waived specials and asked for general damages only. The jury liked our client and Paul Jain, MD and Andrew Blumenfeld, MD were fantastic on his TBI and headaches. I think they proved to the jury that this was a debilitating injury. Our case was made much more difficult by the fact that our client was 78, had 3 heart attacks, and two asymptomatic strokes, as well as a long history of orthopedic issues. We also had Dean Dellis on neuropsych but our client's self-reported cognitive issues were not present on any testing. Dellis did a fantastic job explaining how chronic pain causes over-reporting of cognitive defects in patients and in closing I got to explain to the jury that the defects were very real to our client, regardless of what a test says. The defense lined up 3 doctors who all said he was basically faking it, but they ended up nixing one of them and having the other 2 significantly tamp down their opinions-even conceding causation where they originally (kind of) contested it. After phase 1 they didn't want to risk more credibility hits. The jury deliberated for 2 hours and returned a verdict of $975,000 in past and $5,000,000 in future pain and suffering. Trying the case in Paso was fantastic. The jurors were smart and attentive. Judge Kelley was the best trial judge I've ever been in front of. He was fair, kept the jury excited, and let you try the case however you wanted. The wine was great too. Opposing counsel was the Olsen Law group out of Thousand Oaks. Both Joel Witzman and Scott Cox were easy to work with despite their goofy, untenable positions during trial. We got along great off the court. I'm proud of Ben for doing a great job with two openings and a handful of witnesses in his second trial. Most importantly - our client was vindicated. He is a smart, successful former piston engineer for automotive racing with a life and career he is proud of. To be called a liar during the litigation and on the stand was hard for him to deal with. The jury got the truth and let SLO know who the liars were. It was a special moment to him - more meaningful than any of the money. We're proud of this one. Onto the next! -Dom
AI Analysis:
The user's real question is a keyword search for 'injury,' and this message directly references an injury — specifically a vertebral artery dissection injury (chronic vs. acute) sustained by a client who rode the Matterhorn and subsequently suffered a stroke. The message contains substantive discussion of an injury in a legal/workers' compensation context, including the nature of the injury, the mechanism of injury, and the need for expert medical review to characterize it. While the message is primarily a referral request for a neuroradiologist rather than a legal analysis of injury law, it does contain meaningful, substantive content about an injury that would be returned in a keyword search for 'injury.' It is not merely a passing mention of the word.
"Barry Novack" Date: August 07, 2026 12:46:00 AM Subject: Neuroradiologist Referral Reply to list Reply to sender Print List: caala-workproduct Sent by: Barry Novack (Reply Privately) Search Hi Listmates, I am looking for a well-qualified neuroradiologist to review images of a vertebral artery dissection and determine if the injury to the vessel is chronic vs acute. Client went on Matterhorn, had neck pain, and stroked out the next day. Thanks. BARRY NOVACK, Esq . Law Offices of Barry Novack 8383 Wilshire Blvd., Suite 830 Beverly Hills, CA 90211 T (323) 852-1030 F (323) 852-9855 C (310) 508-5400 novack@novacklaw.com THIS E-MAIL MESSAGE, INCLUDING ANY ATTACHMENTS, IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL AND DESTROY ALL COPIES OF THE ORIGINAL MESSAGE. THANK YOU.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message discusses a $1.55 million verdict involving a personal injury case with a mild TBI (traumatic brain injury), a fall with no witnesses, and an elderly plaintiff with dementia/Alzheimer's. The message directly involves injury-related content — specifically a premises liability fall resulting in a TBI — which is substantively responsive to a search for 'injury.' The message provides practical litigation details about an injury case including the nature of the injury, challenges faced, and the verdict outcome, which would be useful to someone researching injury cases or verdicts.
"Marilyn Listserve" Date: August 05, 2026 8:56:00 PM Subject: Re: $1.55 Million Verdict - Glendale Courthouse Reply to list Reply to sender Print List: caala-workproduct Sent by: Marilyn Smith (Reply Privately) Search Fantastic result, thanks for the additional information. That release would have stopped almost anyone else from taking the case. Congratulations on persevering and getting a great result. Marilyn M. Smith Marilyn Smith Law APC 301 E. Colorado Blvd., Suite 620 Pasadena, CA 91101 V: 626-683-8102 www.marilynsmithlaw.com This email does not constitute particularlized legal advice and is intended for informational or work product discussion purposes within a closed listserve. It is not to be distributed outside of the CAALA Listserve. This email address is used only for Listserve purposes. To contact me directly, please send an email to Marilyn@Loomms.com . From: Joshua Molchan (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, August 5, 2026 6:39 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] $1.55 Million Verdict - Glendale Courthouse List: caala-workproduct Sent by: Joshua Molchan (Reply Privately) Search All, Following up on Dylan's post below to tell everyone a bit more about the case. - Shorter, Less Expensive Trials - Thoughts From My Recent Trial. The client had felonies, he has gang tattoos on the back of his hands and forearms, he signed and authenticated a release, mild TBI symptoms with a elderly plaintiff with dementia/Alzheimer's, no evidence of how he fell or what he tripped on, no witnesses to the fall, and a conservative jury pool in Glendale. The perfect recipe for a good verdict. We tried the case in front of Judge Ralph Hofer, Department D, Glendale Courthouse. The Defense lawyer was Lorin Snyder who is in-house for Farmer's. He is very nice and easy to work with. Judge Hofer was a bit rusty for a jury trial. We only got 30 minutes for voir dire, no mini opening (does not care about the statute), and he "never" pre-instructs the jury before opening statement. He denied almost every cause challenge on both sides even when they were about as straightforward as they come. Also, he does everything possible for you to settle your case. He dragged us into 5 separate FSCs and each time he would ask us to sit in a conference room with Defense counsel and try to settle the case. He also required both our client and a defense insurance adjuster to personally appear at each Final Status Conference. FACTS 81-year-old Plaintiff was walking down the outside stairs at his second-story apartment when his foot caught on "something" on the second step causing him to fall down the stairs and hit his head at the bottom. He wasn't holding onto the handrail because he had his keys in one hand and his phone in the other. He was not paying attention to the next step. Nobody saw him fall. Nobody knows what he actually tripped on. His wife drove him to the ER where they found a small bump on his forehead but no bleed on the CT scan and sent him home. About three weeks later, Plaintiff told his landlord/defendant about the fall and said he couldn't work full time so he needed $1,500 to cover rent at his auto body shop. The landlord/defendant went and had an attorney draft a release, showed up a week later with a $1,500 check, and told Plaintiff he'd get the money if he signed. Plaintiff didn't read it, didn't have a lawyer look at it, signed his name, and cashed the check. That release obviously turned out to be a huge problem. (We beat a MSJ on it so if you ever run into this issue, I would be happy to share it.) Three weeks after that, Plaintiff 's headaches got much worse and he drove himself back to the ER. This time the imaging showed a moderate acute subdural hematoma and the next day he underwent a right frontal craniotomy to relieve the pressure. Surgery went well. Since then he's just kept up with his neurosurgeon, neurologist, and PCP. Plaintiff's TBI symptoms post incident essentially mirrored someone that was suffering from dementia and early onset Alzheimer's. So much so that his treating neurologist prescribed him medication for early onset dementia to help his memory issues. Plaintiff's complaints at the time of trial were headaches once per month and random instances of forgetfulness. LIABILITY The stairs Plaintiff fell on hadn't been touched since they were built in 1996. A month after the fall, the landlord tore them down and rebuilt them. That left us with nothing but a few photos Plaintiff took a few days after the fall to work with as evidence because Judge Hofer ruled the rebuilt stairs were a subsequent remedial measure and would not budge. He would not even entertain oral arguments or trial briefing on the exceptions. The bigger liability fight was over the release. I have attached the release to this post and encourage you to take a look at it and tell me what your thoughts are because 9/12 jurors thought it meant nothing but 3/12 said it was clear and convincing enough to meet the requirements of a waiver. The Defense told the jury they should award $0 because Plaintiff had signed this release. Both sides had real exposure here. The adjuster seemed to think the release was very clear. It had a title, a date of loss, a short description of the incident, and a 1542 clause, etc. There was definitely enough to lose sleep over. Of course, Gary Dordick was not too concerned with it and saw it as what he calls "Blood in the Water". We used it to tell the full story to the jury. Judge Hofer gave CACI 336 slightly modified on the release issue. We argued for CACI 320 "Interpretation - Construction Against Drafter" but Hofer said no. Question 1 on the verdict form asked the jury whether Plaintiff had waived his right to sue the Defendant. Jurors told us afterward that it was obvious nobody actually understood what they'd signed, so they couldn't call it clear and convincing evidence of a waiver. DAMAGES Plaintiff is now 83 and a lot of his symptoms look almost identical to what you'd see in an average 83-year-old in the early stages of dementia or Alzheimer's. Proving that his cognitive decline traced back to the fall and not just ordinary aging was very difficult especially considering the fact that our client is an old school auto mechanic that didn't complain about anything. This is where Dr. Daniel Franc's testimony came in which was very good. He was able to explain the brain injury to the jury and basically say that in reality, "the lights might be on but nobody is home". Dr. Franc's presentation with the jury and his model brain was very effective. Another issue we had was our jury struggled to understand why a man who had been living independently for three years since his brain surgery suddenly needed millions of dollars in future care. Two jurors told me afterward, almost apologetically, "We thought this type of care was for rich people and not something everyone could afford." The defense went after our experts the way you'd expect. They hit Dr. Franc, our neurologist, for having only physically examined Plaintiff once in person, with every other evaluation done over Zoom. They went after Mark Burns on the theory that his opinions were unreliable because he never personally measured the stairs Plaintiff tripped on. Of course he didn't because the stairs were torn down almost immediately after the fall, before anyone had the chance. Burns's measurements came straight from a handyman's deposition we'd taken a year earlier that did the remodel. We argued to Judge Hofer that by going down this road, defense had opened the door to letting us ask Burns on re-direct why he couldn't measure the stairs. Hofer shut it down right away. Tough ruling to take in the moment but Gary Dordick reminded us afterward you end up thanking the judge for every bad ruling he gives once you get a good verdict because it makes the verdict that much harder to take away from you on appeal. PRE-TRIAL The landlord/defendant carried a $1M underlying policy and a $2M umbrella, both through Farmers. After mediation we came down to $950k and they came up to $525k. A few weeks before trial, we sent a last-chance 998 for $900k. No response. Right before voir dire, they moved to $625k. THE VERDICT As Dylan mentioned above, the first question we got from the jury was a request for a calculator. What he didn't mention was that after the jury's second question (requesting a readback of Dr. Franc's future care recommendations) defense counsel looked over at me and simply said, "Merry Christmas." About an hour after that, three buzzes…we had a verdict. • $719,495.00 - Future Economic Damages • $225,000.00 - Past Non-Economic Damages • $525,000.00 - Future Non-Economic Damages • $80,778.87 - Stipulated Past Medical Specials • $1,550,273.87 - Total Dylan Dordick and I are incredibly fortunate to be able to call our dads before, during, and after trial to share the good, the bad, and the ugly. I want to give a special thank you to our dads, Jeff Molchan and Gary Dordick, for their guidance, "wisdom", and support that contributed to the verdict. At the end of the day, our facts were not great and some of the judges rulings were wrong but our client is a good person that deserved this verdict and I have no doubt the jury was proud to give him every dollar they did. Cheers, Josh Molchan
AI Analysis:
The user's real question is a keyword search for 'injury,' and this message directly involves a catastrophic injury case. The message discusses a workers' compensation/personal injury scenario involving an insurer (Aspire) offering policy limits in response to a demand arising from a catastrophic injury, issues around an affidavit of no other insurance, course and scope, insured cooperation obligations, potential bad faith exposure, and the absence of UM coverage for the client. While the message is a specific case inquiry rather than a general legal treatise on injury law, it substantively addresses legal issues arising from an injury case — including insurer obligations, bad faith arguments, and practical strategies when a client has suffered a catastrophic injury with no UM coverage. It provides meaningful legal context relevant to the keyword 'injury' in a workers' compensation/personal injury practice setting.
Mates: I have an unfortunate situation arising from a catastrophic injury case. Aspire is quickly offering limits in response to a demand but cannot provide a notarized affidavit. This is their response: "We have attempted to get signature with 3rd party vendor but insured is not willing to sign but hte documents have been left with our insured." I know an insured has to cooperate with his or her insurer and Aspire is representing that they are trying to comply with this demand. Aspire has already retained Leach and McGreevy even though we are not in litigation. Is there any argument that Aspire is exposing its insured? Anything I can do on my end given my client's unfortunate situation and no UM. -- Morris Chichyan, Esq. Managing Attorney CHICHYAN LAW APC 818-488-9448 Morris@chichyanlaw.com www.chichyanlaw.com 400 N Brand Boulevard, Suite 840, Glendale, California 91203 IMPORTANT: The contents of this email and any attachments are confidential. They are intended for the named recipient(s) only. If you have received this email by mistake, please notify the sender immediately and do not disclose the contents to anyone or make copies thereof.
AI Analysis:
The user's real question is a keyword search for 'injury,' and this message directly and substantively involves injury content. The message describes a plaintiff who sustained a likely rotator cuff tear (ongoing shoulder injury requiring significant treatment), facial contusions, blurred vision, and other bodily injuries from a nightclub security assault. A second patron sustained a facial fracture. These are concrete, described injuries central to the message's purpose. While this is a referral post rather than a legal analysis or discussion of injury law, it does contain substantive information about the nature, extent, and ongoing status of physical injuries, which directly relates to a search for injury-related content.
Seeking to refer a May 2026 nightclub security assault case involving a plaintiff who was beaten by multiple security guards and an associate/friend of the guards. Police responded and arrested the associate, although the criminal charges were later dropped. Video captures much of the incident. The plaintiff likely sustained a rotator cuff tear. He also suffered contusions to the face and some other bodily injuries, including some blurring vision. Most of it improved but t he shoulder tear remains symptomatic and may require significant additional treatment. A second patron was also assaulted and sustained a facial fracture but he's generally resolved. The Kopple Law Group, Inc. 8938 W. Pico Blvd. Los Angeles, CA 90035 323-391-1554 (direct) 323-391-1552 (main) 323-391-1553 (fax)
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message directly involves a personal injury/premises liability case involving a patient fall at Cedars-Sinai resulting in a broken hip and hip replacement, settled for $1,250,000. The message discusses substantive legal and practical issues arising from that injury case, including IHSS caregiver eligibility, life care plan considerations, and the MICRA collateral source rule ruling. While the message is not answering a specific legal question about injury law, it does contain substantive information about an injury case — its facts, legal issues, and outcome — which is directly relevant to a broad keyword search for 'injury.' The message would be useful to someone researching injury cases, particularly those involving premises liability, life care plans, and IHSS caregiver issues.
"Marilyn Listserve" Date: August 04, 2026 4:31:00 PM Subject: Re: Patient Falls at Cedars, Broken Hip, Hip Replacement- Settled for $1,250,000 Reply to list Reply to sender Print Great win!! Congratulations. For future cases with IHSS issues, keep in mind that a person is eligible only if receiving Medi-Cal, AND the IHSS worker is not necessarily a trained caregiver, such as a CNA or LVN. It usually is a family member who will do grocery shopping, cooking, light housekeeping, and assistance with some ADLs. But the caregiving on lifecare plans usually calls for more skills/training. Also, IHSS is currently limited to 283 hours/month but for 24/7 care it’s approximately 720 hours/month. Marilyn M. Smith Marilyn Smith Law APC 301 E. Colorado Blvd., Suite 620 Pasadena, CA 91101 V: 626-683-8102 www.marilynsmithlaw.com This email does not constitute particularlized legal advice and is intended for informational or work product discussion purposes within a closed listserve. It is not to be distributed outside of the CAALA Listserve. This email address is used only for Listserve purposes. To contact me directly, please send an email to Marilyn@Loomms.com . From: Robert Kahn (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Monday, August 3, 2026 9:32 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Patient Falls at Cedars, Broken Hip, Hip Replacement- Settled for $1,250,000 List: caala-workproduct Sent by: Robert Kahn (Reply Privately) Search Interesting issue as to whether IHSS payments to past and current caregiver (collateral source) were admissible pursuant to MICRA exemption to collateral source rule. Two weeks ago defense said Cedars would not pay a penny for life care plan because current care giver being paid by IHSS. Would have gutted my $1.5 million life care plan (13.4 years of caregiving). Judge ruled this morning the payments were not covered by MICRA exemption to collateral source rule and could not come into evidence. Case quickly settled just before jury selection started today. Another one for the good guys. 😊 Robert Robert A. Kahn, Esq. Trial Lawyer R OBERT K AHN L AW Robert@RobertKahnLaw.com 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 91367 (818) 888-9171 (818) 888-7611 Serious Personal Injury, Wrongful Death, Medical and Legal Malpractice THIS ELECTRONIC MESSAGE IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED, AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL. IF YOU ARE NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS TRANSMISSION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR BY TELEPHONE AT (818) 888-9171, AND DESTROY THE ORIGINAL TRANSMISSION AND ITS ATTACHMENTS WITHOUT READING OR SAVING THEM TO DISK. THANK YOU. P Please consider the environment before printing this e-mail
AI Analysis:
The user's real question is a keyword search for 'injury.' This message directly and substantively discusses injury in a legal/workers' compensation-adjacent context: it describes a plaintiff who sustained soft tissue injuries in a low-impact sideswipe collision, details the verdict obtained ($479,630.32), references the defense's denial of causation related to the injuries, and discusses litigation strategy around injury claims (998 offers, cost of proof sanctions, deposition conduct). The message contains meaningful substantive content about injury — not merely a passing mention — including the nature of the injuries (soft tissue), the impact scenario (sub-5mph sideswipe/MIST case), and how injury causation was contested at trial. A reader searching for information about injury would find actionable and illustrative content here regarding how soft tissue/low-impact injury cases are litigated and valued.
"Cyrus Shahriari" Date: August 04, 2026 2:41:00 PM Subject: $479,630.32 Verdict Against LACMTA - Bus v. Auto - Sub 5mph Sideswipe (MIST) Reply to list Reply to sender Print List: caala-workproduct Sent by: Cyrus Shahriari (Reply Privately) Search All, I am happy to report that I obtained a verdict against the LACMTA last Friday after two weeks of trial at Mosk in Dept. 730 (Judge Giza). The jury awarded a total of $479,630.32. While this is a small amount compared to what I typically see on the list serve, the case involved a low impact sideswipe and soft tissue injuries, and we are very happy with the result. We 998'd Metro for $190k just before designating experts, so this award should be increased significantly. We are also seeking cost of proof sanctions because the defense denied liability and causation from the beginning. Defense 998'd us for $50k just before trial. The defense attorney handling the case was Arthur Preciado. While I'm not thrilled to report this, Preciado was rude throughout the case (repeatedly telling me he's tried many cases, seen it all before, and my client's injuries were BS) and used the discovery process to harass her, including taking a ridiculous and unnecessary 7-hour deposition. I've seen plenty of extremely pro defense/jaded types who hate all plaintiffs having started my career at a defense firm where I worked for about a year, but I have to say Preciado takes the cake. With that said, as bad as he was during discovery and pretrial work, he was somewhat better to work with during trial and generally professional on meet and confer issues, etc., although he will use every defense trick in the book. The Incident: plaintiff's car (Mazda CX5) was stopped in traffic on Sunset Blvd. near Silver Lake area when she felt what she described as a "nudge" in the LACMTA investigation report on the night of the incident (less than ideal word choice). The bus clipped the rear of her car and then caused damage across the passenger front door, wheel well and front right of her car. The bus was going 5mph initially, and the defense argued at trial the impact occurred at 1mph. Total parts replaced on the client's car was $829 ($5,001.32 total bill to repair the car). The Defense: Metro denied liability throughout the case and relied on an internal Metro assessment on the night of the incident finding "no new damage" on the bus after the collision (quick comment on this - the Metro employee who did the bus damage assessment after the incident conceded at depo that there was poor lighting when she did her assessment, but then she testified at trial that lighting wasn't an issue which was a gift for cross). Other than that and our client being the only witness to the incident, Metro's position was unclear until expert discovery. They hired accident reconstructionist Harm Jansen who concocted an entirely new theory arguing that plaintiff's vehicle was overtaking the bus, when she had been consistent from day 1 that her car was stopped when the incident occurred. He presented a PowerPoint at trial showing damage to her car that the defense contended demonstrated that she was overtaking the bus. One key fact they relied on was photos of the sideview mirror on the passenger side that were taken when the mirror was folded. Jansen claimed that the position of the mirror indicated she was overtaking the bus, even though the only damage on the mirror was a couple of scratches. I argued during his cross and in closing that you would expect to see structural damage if this was one of the main areas of impact. We also had testimony that a friend put the mirror in the folded position, and Jansen conceded that all his opinions are "probabilities" at best and not certainties. Metro's Failure to Preserve Video: Metro is required to preserve video per Gov. Code § 26206.8. Metro employees also testified that buses are equipped with cameras. However, for whatever reason, they did not preserve video in our case. I absolutely hammered them on this throughout trial, and I think this was key for the jury. We got CACI 203 and 204 instructions, and I prepared a special based on § 26206.8. Notes for Anyone Litigating Against Metro: I would make sure to press them as hard as possible for video footage in discovery. I would also demand for Vehicle Condition Report Cards - these are cards filled out by a driver any time before they take possession of a bus. There can be up to 3 cards for each day to account for 3 separate shifts. Also press them for damage assessment reports after the incident. They hid the cards and damage assessment report from us for much of discovery, so I would assume needing to meet and confer and push hard for these. Plaintiff's Injuries: neck injury for straightening of cervical spine causing muscle spasms, partial tears in both shoulders, aggravation of preexisting headaches (client had extensive history of head injuries/migraines - her neurologist at Cedars unfortunately did not tie her new headaches - cervicogenic headaches - to our incident and testified there were multiple factors causing this). While this meant we could not include things like trigger point injections or new medications to manage the cervicogenic headaches in the life care plan, the fact that plaintiff was receiving regular ongoing treatment from her neurologist demonstrated that her injuries were real. The defense and their expert Thomas Grogan MD (pediatric ortho) argued somatization and that her injuries were basically made up, the neurology treatment helped validate everything. Damages Claimed at Trial: $19,800 in past medical expenses on a lien (insurance past expenses waived), $5,001.32 for property damage to the car, $9,000 for past Ubers/transportation costs that the client needs to get to her jobs (she's a tv writer). We presented a future lifecare plan based on 2 shoulder surgeries recommended by Dr. Kabaei (although he testified that she needs the right and maybe the left which they would determine after the right shoulder surgery - life care plan totaled $245,829), future economic damages for transportation since she has a hard time driving bc of muscle spasms that cause her headaches, and past and future general damages. We did not claim damages for lost wages/earnings or earning capacity whether past or future. Our Experts: Farzin Kabaei MD (treating only for this case; ortho at DOCS Health - he's the man, does a good split of plf and defense; Grogan testified he is "excellent" and "ethical" as they know each other and worked in the same office before); life care planner Brook Feerick (first time working with her - did great at trial; credible; would happily work with her again), economist Justin Klinkenberg of Formuzis Hunt & Lanning, and Arthur Croft (accident recon + biomechanic designated in response to the defense experts). Defense Experts: Thomas Grogan MD (ortho - opined that plf needed nothing for her shoulders, she only had tendinosis and any shoulder issues were pre-existing), Harm Jansen (accident recon frequently hired by Metro - slippery guy and thankfully the jury didn't buy his story that would have tanked the case for us), and Tyler Shaw (biomechanic who analyzed forces from a general sense - analyzed the incident as having extremely low delta v and similar force to going over a speedbump, etc). Our Judge: we tried the case before Judge Alexander Giza (Dept. 730) who recently took over for Judge Tiana J. Murillo. She continued our case multiple times, and thankfully Judge Giza was ready and willing to try cases. He started another one the Monday after ours ended last Friday. Solid and thoughtful judge who will let you try your case. Overall fair rulings; reviews the law and the papers. Would happily try another case in his courtroom. The Trial: I tried this case by myself as I recently split off from a partner I had for several years due to having different practice areas. There were about a dozen witnesses. We got a decent pull for the jury although I had to exercise all my peremptories. Preciado requested a questionnaire, which was helpful mainly for me to root out jurors who said jury awards are too high. Because of the questionnaire, I knew the next set of jurors did not answer that verdicts are too high, and ultimately we got a solid panel with a good mix of different people. I got out in front of bad facts during voir dire like the low impact, and this didn't seem to be an issue for them later once they got the uniquely susceptible jury instruction. During trial, Preciado repeatedly used words like "smudge" and "scratch" to describe damage on photos of my client's car and to downplay the incident. To counter this, I focused on collision repair records that included replacement for rear and front bumper covers as well as a little bit of work on high strength steel (HSS). Although there was only $829 in parts replaced, the jury was not swayed by the lack of significant property damage or our client's use of the word "nudge" in her statement to Metro. Re: injuries, Kabaei testified that she needed a shoulder arthroscopic repair on the right and possibly the left shoulder due to injuries that he had no reason to believe were caused by anything other than the incident. The injuries formed the basis for our life care plan. Client had no prior record of shoulder injuries despite an extensive medical history, and despite the defense pointing to numerous other accidents and incidents that could have caused her injuries, I closed by highlighting the fact that the defense never showed them anything demonstrating a prior shoulder injury (in closing I explained I could never prove a case based on just speculation and not connecting the dots - and that's what they're asking you to do). As others have noted in here, Preciado's callous and overly defense strategy tends to backfire on him at trial. Many jurors did not like how he crossed my client and some even said it was "hard to watch." I mostly let him do his thing unless there was something significant and trusted the jury would dislike his approach. The jury awarded all the past medical expenses we claimed, past property damage, and past economic loss for rideshare. The jury awarded the full amount of Brook Feerick's lifecare plan and $100,000 for other future economic loss (future rideshare/transportation only - a much bigger number than we expected even though I acknowledged in closing that we are not claiming damages for lost wages/earning capacity). The jury only awarded $50k for past general damages and $50k for future economic damages. They were deliberating late on a Friday afternoon, and I think they had a hard time coming to consensus on general damages and wanted to leave as we received the verdict at 445pm when they were told they would have to come back on Monday. I also think they felt they awarded such significant numbers for economics that they thought $100k in general damages was sufficient. With that said, presenting general damages is one area of trying cases where I can improve and that is one of my main takeaways from the trial. Key Takeaways: not overreaching was the right move in this case because of the low-impact nature of the incident. By being able to represent we were not claiming lost wages/earning capacity or neurology medical expenses as the Cedars neurologist said there were multiple factors to the headaches, this made the shoulder injuries and lifecare plan much more credible and ultimately got our client a great result. We also had to explain why she did not get the future surgeries - Kabaei helpfully framed this as them taking a conservative approach where surgery was the last option after treating her for two years. Re: Voir Dire - disclosing bad facts early helped, as well as addressing bad facts ourselves on direct to take the punch out of defense cross. Notes for myself: save more time for general damages in closing and make a more concise Powerpoint. I could have used another 15 minutes for closing despite having 45 minutes, which went incredibly fast. Thank Yous: first and foremost I have to shout out Arash Homampour who has been willing to take my questions ever since I was a first-year defense attorney who attended a depo at his office about 12 years and asked for a moment to meet with him after the depo, which he graciously took. Arash's advice throughout my career has been invaluable and ultimately inspired me to start my own firm after working in defense/commercial litigation. I want to thank Natalie Weatherford who took a few minutes at a birthday party to gameplan my theme (taking responsibility for your actions - simple, straightforward and exactly on point). Thank you, Brian Poulter, for being available for a few quick questions the week before trial. Finally, while I don't believe we've met before, I want to thank Minh Nguyen for posting a closing argument PowerPoint on the document bank. I pulled some helpful images illustrating the difference between criminal v. civil burden of proof that I think was key for the jury reaching a verdict in our favor, as our client was the only witness of the incident. Overall a great experience and look forward to more. Always a lot to learn and build upon moving forward. Immense gratitude for the opportunity and the favorable outcome. Finally, I want to take a moment to give some flowers to a few great experts in another case I tried last year. That case involved a commercial building in downtown where 11 artists rented studio space on the 2nd and 3rd floors until it burned to the ground after a fire started on the 1st floor, causing the artists to lose their life's work. The case settled after 2-weeks of trial for $1.26M despite no insurance being available following a concurrently federal dec relief action filed by the defendant's insurer. In a nutshell, the landlord failed to obtain a certificate of insurance from a smoke shop tenant on the first floor where the fire originated, which was a condition precedent to coverage under the landlord's policy applying. The Daily Journal covered this one for anyone interested to see more about the case (https://www.dailyjournal.com/article/385269-artists-settle-for-1-26-million-in-little-tokyo-fire-lawsuit). Defense attorneys were Jack Reinholtz and Gopal Patel of Prindle Law--both gentlemen. The experts from the fire case who I want to shout out in particular are: Robert Rowe (fire expert and loved by the jury), Stephen J. Donell (my go-to for all things real estate/property management related, including mold cases), the well-known Mark Burns, Nelson Algaze of Shlemmer+Algaze+Associates Interiors & Architecture, Inc. (not a frequent expert - opined on space planning, tenant improvement and permitting process from the perspective of someone designing the space), Kevin Zweyer Anderson of AAA of Anderson Fine Art Appraisals, costume designer Elizabeth Estervig and Garry Kitchen of SGK Service Inc. (videogame expert who we used to opine on value of source code created by an architect who uses source code for large public displays). Best, Cyrus Cyrus Shahriari The Shahriari Law Firm, P.C. dba My Guy Cy 6700 S. Centinela Ave., 2nd Fl. Los Angeles, CA 90230 Tel.: (310) 424-5557 Fax: (310) 597-4626 E-mail: cyrus@myguycy.com www.myguycy.com
AI Analysis:
The user's real question is a keyword search for 'injury,' and this message directly involves a serious personal injury case — a patient fall at Cedars-Sinai resulting in a broken hip and hip replacement, settled for $1,250,000. The message discusses substantive legal issues related to the injury case, including the MICRA collateral source rule, IHSS payments, and life care planning for ongoing caregiving needs resulting from the injury. While the message is not a general discussion of injury law principles, it does contain substantive information about an injury case outcome and a key evidentiary ruling that affected the settlement, making it meaningfully relevant to the keyword 'injury.'
"Robert Kahn" Date: August 03, 2026 11:32:00 PM Subject: Patient Falls at Cedars, Broken Hip, Hip Replacement- Settled for $1,250,000 Reply to list Reply to sender Print Interesting issue as to whether IHSS payments to past and current caregiver (collateral source) were admissible pursuant to MICRA exemption to collateral source rule. Two weeks ago defense said Cedars would not pay a penny for life care plan because current care giver being paid by IHSS. Would have gutted my $1.5 million life care plan (13.4 years of caregiving). Judge ruled this morning the payments were not covered by MICRA exemption to collateral source rule and could not come into evidence. Case quickly settled just before jury selection started today. Another one for the good guys. 😊 Robert Robert A. Kahn, Esq. Trial Lawyer R OBERT K AHN L AW Robert@RobertKahnLaw.com 5550 Topanga Canyon Boulevard, Suite 200 Woodland Hills, CA 91367 (818) 888-9171 (818) 888-7611 Serious Personal Injury, Wrongful Death, Medical and Legal Malpractice THIS ELECTRONIC MESSAGE IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED, AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL. IF YOU ARE NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS TRANSMISSION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR BY TELEPHONE AT (818) 888-9171, AND DESTROY THE ORIGINAL TRANSMISSION AND ITS ATTACHMENTS WITHOUT READING OR SAVING THEM TO DISK. THANK YOU. P Please consider the environment before printing this e-mail
AI Analysis:
This message relates to the user's question about 'injury' by discussing post-traumatic cervical dystonia caused by whiplash neck injuries. The message provides substantive medical-legal information about how peripheral injuries can trigger neurological responses leading to cervical dystonia — a specific type of work-related injury mechanism. It explains the causal chain from whiplash/neck injury to abnormal involuntary muscle contractions, which is directly relevant to understanding this type of injury in a workers' compensation context. However, it is primarily a request for an expert witness recommendation rather than a comprehensive answer about injury law or case strategy, which limits its relevance somewhat.
"Darian Bojeaux" Date: August 03, 2026 9:26:00 PM Subject: Need Cervical Dystonia Expert Reply to list Reply to sender Print List: caala-workproduct Sent by: Darian Bojeaux (Reply Privately) Search Can anyone recommend a cervical dystonia expert? Post-traumatic cervical dystonia episodes can be caused by whiplash neck injuries up to a year after an accident due to a severe peripheral injury which alters sensory feedback to the central nervous system which then triggers abnormal, involuntary muscle contractions in the neck. For instance, a person's neck muscles may contract involuntarily, forcing their head down and to the side, and they will be unable to move their neck due to the excruciating pain which may continue for some time. Thank you. Darian Bojeaux 475 Washington Boulevard Marina del Rey, CA 90292 (310) 270-7221
AI Analysis:
The user's real question is a broad keyword search for 'injury,' and this message does involve injury claims in the context of a third-party auto case with multiple claimants and UIM coverage. The message discusses a practical strategy for handling a situation where multiple injury claims exist and the underlying policy limits are insufficient, which is directly related to injury claims. However, the message is fairly specific to UIM/third-party auto settlement strategy rather than addressing a broad or specific legal question about 'injury' in a workers' compensation context. It provides some substantive information about injury claims and how they interact with policy limits, making it partially to substantially relevant depending on what aspect of 'injury' the user is researching.
"Nigel A. Whitehead" Date: August 03, 2026 4:34:00 PM Subject: Re: Question on how to whether a carrier can delay trying to settle a third party auto case that has a value over policy limits if there are other injury claims pending where the value has not yet been determined. Reply to list Reply to sender Print In a recent similar situation, there were 3 claimants. Our client was the only one with substantial UIM. We agreed to take a very small portion of the underlying $30k. The result is the same – we have the UIM policy limit available minus the small offset. If the underlying policy is exhausted and you have sufficient UIM it doesn’t matter to you how the money is split. Please REPLY ALL Nigel Whitehead ERNST LAW GROUP 1020 Palm St. San Luis Obispo, CA 93401 T. 805.541.0300 F. 805 541-5168 C 805.431.2710 naw@ernstlawgroup.com Member of CAOC, CAALA, CCTLA, AAJ and ABOTA THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: Sarah Havens (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Monday, August 3, 2026 12:28 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Question on how to whether a carrier can delay trying to settle a third party auto case that has a value over policy limits if there are other injury claims pending where the value has not yet been determined. List: caala-workproduct Sent by: Sarah Havens (Reply Privately) Search Exactly what Howard said. EXACTLY. I get these questions all the time. Sarah Allison Havens, Esq. Trial Lawyer HAVENS INJURY LAW, sophospsmartbannerend List: caala-workproduct Sent by: Sarah Havens (Reply Privately) Search Exactly what Howard said. EXACTLY. I get these questions all the time. Sarah Allison Havens, Esq. Trial Lawyer HAVENS INJURY LAW, INC. 535 N. Highway 101, Suite I Solana Beach, CA 92075 E: Sarah@HavensInjuryLaw.com W: HavensInjuryLaw.com P: 619-446-9476 F: 619-331-2193 On Sunday, August 2, 2026 at 06:01:19 PM PDT, Howard Blumenthal (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search When there are three or more claimants in a split policy, they cannot tender 30,000 and leave less than a single policy limit available. You have two choices a joint demand with all the claimants or what I do is exactly what the adjuster is doing here where I say we will accept a global tender the policy limits with the insurance company to pay for mediation to divide it up. You have UIM as long as your case is within the value of UIM it shouldn’t matter to you find out who the plaintiff attorney is talk to them, get them to submitted demand split the money based on whether they have UIM or not, and move on. Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059 On Aug 2, 2026, at 2:09 PM, Richard Weiss (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Richard Weiss (Reply Privately) Search Hello All, I have a third party auto case where Geico insures the third party. My client and two others have made injury claims that are worth above the policy limits. My client's claim has a value of at least $50,000.00. We sent a policy limits demand, including all supporting medical records, wage loss, etc., about 5 days ago. My client has UIM. The Geico adjustor calls me Friday and states that the policy is 30/60, will I take less than the policy limit amount, he offered to tender the global policy limit amount for all claimants, and said I could negotiate the distribution of the $60,000.00 with counsel who represents a driver and passenger in another vehicle each making injury claims. I replied and said what are the claimed injuries for the other claimants. The adjustor replied and said he did not know, nor has that party made any settlement demands or settlement overtures. I told the adjuster that we want the $30,000.00 limit per person, conditioned on the insured/driver's declaration verifying the limits, with a certified copy of the declaration page, there being no other insurance, and that he was not within the course and scope of any employment. The adjustor told me that he will have to speak with counsel, who may take over the handling of the claim. There is about 30 days left on the period to tender policy limits under CCP Section 999. Here are my questions: 1. Can the adjustor properly decline or delay paying my client's policy limits demand until he learns about the nature of other claimants' injuries and potential value of each of their claims? 2. Can the carrier file an action and interplead the policy limits now to protect itself? Has anyone seen this done in this type of auto claim where unknown injuries of claimants are not yet determined? 3. What can I do, if anything, to open up the policy limits? 4. Is there any value in contacting the other injury claimants' counsel to see if an agreement can be made to distribute the limits? 4. While I have UIM available as an option so we could potentially take a little less than the policy, I also want to avoid, if possible, a situation where the other claimants do nothing until the statute approaches, delaying my client's resolution, or whether I can firmly stick to the policy limits demand and get Geico to pay it. All suggestions/thoughts are welcomed and appreciated. Thank you PLEASE NOTE OUR NEW OFFICE NUMBER BELOW Richard Weiss, Esq. rweiss@richardweisslaw.com LAW OFFICES OF RICHARD WEISS 10350 Santa Monica Boulevard, Suite 295 Los Angeles, CA 90025 310-734-7581 ph. 310-553-0036 ph. 310-553-0067 fax Nevada Office: 10161 Park Run Drive, Suite 150 Las Vegas, Nevada 89145 702-508-9516 ph. 702-508-9517 fax THE CONTENTS OF THIS MESSAGE ARE CONFIDENTIAL WORK
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses a third-party auto bodily injury (BI) claim involving lumbar epidural steroid injections and physical injury to a claimant, and the response references 'personal injury attorney' practice in California. The message substantively involves a personal injury/bodily injury context — Tesla withdrawing BI offers after updated medical evidence including injury treatment. While the message is primarily about bad faith claim handling strategy and AI-assisted letter drafting rather than a focused discussion of injury law or injury-related legal standards, it does contain substantive content directly tied to a physical injury claim scenario. It partially addresses the 'injury' topic in a workers' compensation and personal injury legal context, though it is more focused on insurer conduct and claim strategy than on injury analysis itself.
"Michael Avanesian" Date: August 03, 2026 3:21:00 PM Subject: Re: Tesla BI Claim Issue Reply to list Reply to sender Print It sounds like they made a mistake. I would follow up with them a few times before filing a lawsuit. I believe Tesla is using AI to do a lot of the work and that if you use ChatGPT or Grok to generate the letter to Tesla, you’ll have a 10x better response rate. I would literally go into Grok and write, “I am a personal injury attorney in California. <insert facts>. Then add something like: I think Tesla made a mistake, I want to trap them in a bad faith case and open the policy but I want to be careful about how I move forward. If they don’t tender their limits, Tesla will be screwed. Help me draft a letter… It’s likely that the software has built in spying for Tesla, so it’ll trigger something on the back end to get you a really good response. Sincerely, www.avianlawgroup.com Michael Avanesian, Esq. Chief Executive Officer Licensed to practice in California and Texas Office: 818-282-8400 Fax: 818-688-5161 e: michael@avianlawgroup.com From: Emma Samyan (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Monday, August 3, 2026 12:53 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Tesla BI Claim Issue List: caala-workproduct Sent by: Emma Samyan (Reply Privately) Search Hi everyone, Has anyone had issues with Tesla withdrawing prior BI offers and closing a claim after a renewed policy limits demand? Tesla has become increasingly difficult/non-responsive on most claims - first and third party. I have a third-party auto claim where liability had been accepted, multiple offers were previously made, and the claimant's vehicle was deemed a total loss. After we served a renewed policy limits demand with updated medicals, including two completed lumbar epidural steroid injections and significant specials, Tesla sent a letter withdrawing all prior offers, stating there is "insufficient support" to establish that the claimed injuries resulted from the loss, and closing the bodily injury claim. The letter did not identify any peer review, IME, medical opinion, biomechanical analysis, or specific record-based reason for the sudden reversal. It also appears to identify a different insured name than the one listed in the claim/demand materials. I am curious whether anyone else has seen this from Tesla recently - specifically, prior offers being withdrawn after a limits demand, generic causation language, claim closure, or inconsistent insured/claim information. We plan on filing would would appreciate any insight or similar experiences. Thank you! Emma
AI Analysis:
The user's real question is a keyword search for 'injury.' This message directly and substantively discusses bodily injury in the context of a third-party auto claim against Tesla's insurer, including lumbar epidural steroid injections, causation disputes regarding claimed injuries, and Tesla's withdrawal of prior bodily injury (BI) offers citing 'insufficient support' to establish that injuries resulted from the loss. The message contains meaningful, substantive discussion of injury-related legal and claims issues — specifically causation challenges, injury documentation (medical specials, ESIs), and bad faith-adjacent insurer conduct regarding injury claims. It is not merely a passing mention of the word 'injury' but rather a detailed factual and procedural discussion centered on an injury claim. This provides substantive content relevant to the keyword 'injury,' though the search is broad and this message addresses only one specific injury claim scenario rather than a general legal principle.
"Emma Samyan" Date: August 03, 2026 2:53:00 PM Subject: Tesla BI Claim Issue Reply to list Reply to sender Print List: caala-workproduct Sent by: Emma Samyan (Reply Privately) Search Hi everyone, Has anyone had issues with Tesla withdrawing prior BI offers and closing a claim after a renewed policy limits demand? Tesla has become increasingly difficult/non-responsive on most claims - first and third party. I have a third-party auto claim where liability had been accepted, multiple offers were previously made, and the claimant's vehicle was deemed a total loss. After we served a renewed policy limits demand with updated medicals, including two completed lumbar epidural steroid injections and significant specials, Tesla sent a letter withdrawing all prior offers, stating there is "insufficient support" to establish that the claimed injuries resulted from the loss, and closing the bodily injury claim. The letter did not identify any peer review, IME, medical opinion, biomechanical analysis, or specific record-based reason for the sudden reversal. It also appears to identify a different insured name than the one listed in the claim/demand materials. I am curious whether anyone else has seen this from Tesla recently - specifically, prior offers being withdrawn after a limits demand, generic causation language, claim closure, or inconsistent insured/claim information. We plan on filing would would appreciate any insight or similar experiences. Thank you! Emma
AI Analysis:
This message relates to the user's question about 'injury' as it directly involves a brain injury case and its downstream medical consequences. The attorney is seeking an expert to establish a causal chain from a brain injury to nonadherence to cardiac medications to cardiac death. The message substantively discusses a workers' compensation death case where brain injury is a central element, making it directly relevant to the topic of injury in a legal/workers' comp context. However, it is a request for expert referrals rather than a substantive explanation or answer about injury law, which limits its full relevance.
"Christopher Gansen" Date: August 02, 2026 8:09:00 PM Subject: cardiologist / internist expert for death case Reply to list Reply to sender Print List: caala-workproduct Sent by: Christopher Gansen (Reply Privately) Search Need to tie brain injury -> nonadherence to numerous cardiac treatment meds -> severe and obvious cardiac death. All documented, including autopsy. Difficult, but not impossible. Have to try. Thanks in advance.
AI Analysis:
The user's real question is a keyword search for 'injury,' and this message directly and substantively discusses injury claims in a third-party auto case context. The message is not merely mentioning the word 'injury' in passing — it centers on multiple injury claims (the client's and two others'), their valuation, policy limits demands under CCP Section 999, and strategic questions about how to handle competing injury claimants. The message discusses the nature and value of injuries as a core element of the legal analysis (e.g., 'injury claims that are worth above the policy limits,' 'what are the claimed injuries for the other claimants,' 'unknown injuries of claimants are not yet determined'). A reader searching for content about injury claims in the workers' compensation or personal injury context would find substantive, practical legal discussion here. However, the confidence is moderate rather than high because this appears to be a question post rather than an answer post — it raises issues about injury claims but does not itself provide authoritative answers or legal analysis resolving those issues.
Hello All, I have a third party auto case where Geico insures the third party. My client and two others have made injury claims that are worth above the policy limits. My client's claim has a value of at least $50,000.00. We sent a policy limits demand, including all supporting medical records, wage loss, etc., about 5 days ago. My client has UIM. The Geico adjustor calls me Friday and states that the policy is 30/60, will I take less than the policy limit amount, he offered to tender the global policy limit amount for all claimants, and said I could negotiate the distribution of the $60,000.00 with counsel who represents a driver and passenger in another vehicle each making injury claims. I replied and said what are the claimed injuries for the other claimants. The adjustor replied and said he did not know, nor has that party made any settlement demands or settlement overtures. I told the adjuster that we want the $30,000.00 limit per person, conditioned on the insured/driver's declaration verifying the limits, with a certified copy of the declaration page, there being no other insurance, and that he was not within the course and scope of any employment. The adjustor told me that he will have to speak with counsel, who may take over the handling of the claim. There is about 30 days left on the period to tender policy limits under CCP Section 999. Here are my questions: 1. Can the adjustor properly decline or delay paying my client's policy limits demand until he learns about the nature of other claimants' injuries and potential value of each of their claims? 2. Can the carrier file an action and interplead the policy limits now to protect itself? Has anyone seen this done in this type of auto claim where unknown injuries of claimants are not yet determined? 3. What can I do, if anything, to open up the policy limits? 4. Is there any value in contacting the other injury claimants' counsel to see if an agreement can be made to distribute the limits? 4. While I have UIM available as an option so we could potentially take a little less than the policy, I also want to avoid, if possible, a situation where the other claimants do nothing until the statute approaches, delaying my client's resolution, or whether I can firmly stick to the policy limits demand and get Geico to pay it. All suggestions/thoughts are welcomed and appreciated. Thank you PLEASE NOTE OUR NEW OFFICE NUMBER BELOW Richard Weiss, Esq. rweiss@richardweisslaw.com LAW OFFICES OF RICHARD WEISS 10350 Santa Monica Boulevard, Suite 295 Los Angeles, CA 90025 310-734-7581 ph. 310-553-0036 ph. 310-553-0067 fax Nevada Office: 10161 Park Run Drive, Suite 150 Las Vegas, Nevada 89145 702-508-9516 ph. 702-508-9517 fax THE CONTENTS OF THIS MESSAGE ARE CONFIDENTIAL WORK
AI Analysis:
The user's real question is a keyword search for 'injury.' This message directly mentions 'injury/body part' in the context of recommending orthopedic specialists who work on lien in Long Beach, categorizing them by injury type (spine vs. extremity vs. hand/wrist). The message contains substantive references to injury types and provides practical information about matching injury type to the appropriate specialist. While the message is primarily a referral recommendation rather than a deep legal analysis of injury-related issues, it does meaningfully engage with the concept of injury type as a central organizing factor in the response.
"Beau Goodrick" Date: July 31, 2026 3:43:00 PM Subject: Re: ORTHO IN LONG BEACH WHO WILL WORK ON LIEN Reply to list Reply to sender Print List: caala-workproduct Sent by: Beau Goodrick (Reply Privately) Search For what type of injury/body part? Hamid Mir and Kasra Rowshan are spine orthos that have (or at least had) offices in Long Beach that have been recommended on this listserv and work on lien. Ronna Parsa and Neil Ghodadro are extremity orthos that takes liens with offices in long beach. There are some orthos who specialize in hand/wrist stuff as well among other specialists, but it's unclear what you're looking for. Beau M. Goodrick, Esq. Attorney OWEN, PATTERSON & OWEN, LLP 23822 W. Valencia Blvd, Suite 303 Valencia, California 91355 Office: 661.799.3899 Ext. 777 Fax: 661.799.2774 Website: www.opolaw.com _____________________________________________________________________ The information contained in this e-mail message may be privileged, confidential, and protected from disclosure. If you are not the intended recipient, any further disclosure, use, dissemination, distribution, or copying of this message or any attachment is strictly prohibited. If you think that you have received this e-mail message in error, please delete it and notify the sender.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses a $1.55 million verdict involving an 81-year-old plaintiff who suffered a fall resulting in a mild TBI (traumatic brain injury), which is directly an injury-related case. The message contains substantive discussion of an injury case including the nature of the injury (mild TBI, fall/trip), case facts, trial strategy, and outcome. However, because the real question is simply a keyword search for 'injury' with no more specific legal question to answer, the message is partially relevant — it clearly involves an injury case and would surface in any injury-related search, but there is no specific legal question about injury law, causation, or injury valuation to directly answer. The message is a trial result/case summary that mentions injury facts but does not provide legal analysis or answer a specific legal question about injury.
"evalenzuela@galipolaw.com" Date: August 06, 2026 10:29:00 AM Subject: Re: $1.55 Million Verdict - Glendale Courthouse Reply to list Reply to sender Print List: caala-workproduct Sent by: Eric Valenzuela (Reply Privately) Search Amazing result great job and awesome write up!!! From: Joshua Molchan (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, August 5, 2026 6:39 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] $1.55 Million Verdict - Glendale Courthouse List: caala-workproduct Sent by: Joshua Molchan (Reply Privately) Search All, Following up on Dylan's post below to tell everyone a bit more about the case. - Shorter, Less Expensive Trials - Thoughts From My Recent Trial. The client had felonies, he has gang tattoos on the back of his hands and forearms, he signed and authenticated a release, mild TBI symptoms with a elderly plaintiff with dementia/Alzheimer's, no evidence of how he fell or what he tripped on, no witnesses to the fall, and a conservative jury pool in Glendale. The perfect recipe for a good verdict. We tried the case in front of Judge Ralph Hofer, Department D, Glendale Courthouse. The Defense lawyer was Lorin Snyder who is in-house for Farmer's. He is very nice and easy to work with. Judge Hofer was a bit rusty for a jury trial. We only got 30 minutes for voir dire, no mini opening (does not care about the statute), and he "never" pre-instructs the jury before opening statement. He denied almost every cause challenge on both sides even when they were about as straightforward as they come. Also, he does everything possible for you to settle your case. He dragged us into 5 separate FSCs and each time he would ask us to sit in a conference room with Defense counsel and try to settle the case. He also required both our client and a defense insurance adjuster to personally appear at each Final Status Conference. FACTS 81-year-old Plaintiff was walking down the outside stairs at his second-story apartment when his foot caught on "something" on the second step causing him to fall down the stairs and hit his head at the bottom. He wasn't holding onto the handrail because he had his keys in one hand and his phone in the other. He was not paying attention to the next step. Nobody saw him fall. Nobody knows what he actually tripped on. His wife drove him to the ER where they found a small bump on his forehead but no bleed on the CT scan and sent him home. About three weeks later, Plaintiff told his landlord/defendant about the fall and said he couldn't work full time so he needed $1,500 to cover rent at his auto body shop. The landlord/defendant went and had an attorney draft a release, showed up a week later with a $1,500 check, and told Plaintiff he'd get the money if he signed. Plaintiff didn't read it, didn't have a lawyer look at it, signed his name, and cashed the check. That release obviously turned out to be a huge problem. (We beat a MSJ on it so if you ever run into this issue, I would be happy to share it.) Three weeks after that, Plaintiff 's headaches got much worse and he drove himself back to the ER. This time the imaging showed a moderate acute subdural hematoma and the next day he underwent a right frontal craniotomy to relieve the pressure. Surgery went well. Since then he's just kept up with his neurosurgeon, neurologist, and PCP. Plaintiff's TBI symptoms post incident essentially mirrored someone that was suffering from dementia and early onset Alzheimer's. So much so that his treating neurologist prescribed him medication for early onset dementia to help his memory issues. Plaintiff's complaints at the time of trial were headaches once per month and random instances of forgetfulness. LIABILITY The stairs Plaintiff fell on hadn't been touched since they were built in 1996. A month after the fall, the landlord tore them down and rebuilt them. That left us with nothing but a few photos Plaintiff took a few days after the fall to work with as evidence because Judge Hofer ruled the rebuilt stairs were a subsequent remedial measure and would not budge. He would not even entertain oral arguments or trial briefing on the exceptions. The bigger liability fight was over the release. I have attached the release to this post and encourage you to take a look at it and tell me what your thoughts are because 9/12 jurors thought it meant nothing but 3/12 said it was clear and convincing enough to meet the requirements of a waiver. The Defense told the jury they should award $0 because Plaintiff had signed this release. Both sides had real exposure here. The adjuster seemed to think the release was very clear. It had a title, a date of loss, a short description of the incident, and a 1542 clause, etc. There was definitely enough to lose sleep over. Of course, Gary Dordick was not too concerned with it and saw it as what he calls "Blood in the Water". We used it to tell the full story to the jury. Judge Hofer gave CACI 336 slightly modified on the release issue. We argued for CACI 320 "Interpretation - Construction Against Drafter" but Hofer said no. Question 1 on the verdict form asked the jury whether Plaintiff had waived his right to sue the Defendant. Jurors told us afterward that it was obvious nobody actually understood what they'd signed, so they couldn't call it clear and convincing evidence of a waiver. DAMAGES Plaintiff is now 83 and a lot of his symptoms look almost identical to what you'd see in an average 83-year-old in the early stages of dementia or Alzheimer's. Proving that his cognitive decline traced back to the fall and not just ordinary aging was very difficult especially considering the fact that our client is an old school auto mechanic that didn't complain about anything. This is where Dr. Daniel Franc's testimony came in which was very good. He was able to explain the brain injury to the jury and basically say that in reality, "the lights might be on but nobody is home". Dr. Franc's presentation with the jury and his model brain was very effective. Another issue we had was our jury struggled to understand why a man who had been living independently for three years since his brain surgery suddenly needed millions of dollars in future care. Two jurors told me afterward, almost apologetically, "We thought this type of care was for rich people and not something everyone could afford." The defense went after our experts the way you'd expect. They hit Dr. Franc, our neurologist, for having only physically examined Plaintiff once in person, with every other evaluation done over Zoom. They went after Mark Burns on the theory that his opinions were unreliable because he never personally measured the stairs Plaintiff tripped on. Of course he didn't because the stairs were torn down almost immediately after the fall, before anyone had the chance. Burns's measurements came straight from a handyman's deposition we'd taken a year earlier that did the remodel. We argued to Judge Hofer that by going down this road, defense had opened the door to letting us ask Burns on re-direct why he couldn't measure the stairs. Hofer shut it down right away. Tough ruling to take in the moment but Gary Dordick reminded us afterward you end up thanking the judge for every bad ruling he gives once you get a good verdict because it makes the verdict that much harder to take away from you on appeal. PRE-TRIAL The landlord/defendant carried a $1M underlying policy and a $2M umbrella, both through Farmers. After mediation we came down to $950k and they came up to $525k. A few weeks before trial, we sent a last-chance 998 for $900k. No response. Right before voir dire, they moved to $625k. THE VERDICT As Dylan mentioned above, the first question we got from the jury was a request for a calculator. What he didn't mention was that after the jury's second question (requesting a readback of Dr. Franc's future care recommendations) defense counsel looked over at me and simply said, "Merry Christmas." About an hour after that, three buzzes…we had a verdict. • $719,495.00 - Future Economic Damages • $225,000.00 - Past Non-Economic Damages • $525,000.00 - Future Non-Economic Damages • $80,778.87 - Stipulated Past Medical Specials • $1,550,273.87 - Total Dylan Dordick and I are incredibly fortunate to be able to call our dads before, during, and after trial to share the good, the bad, and the ugly. I want to give a special thank you to our dads, Jeff Molchan and Gary Dordick, for their guidance, "wisdom", and support that contributed to the verdict. At the end of the day, our facts were not great and some of the judges rulings were wrong but our client is a good person that deserved this verdict and I have no doubt the jury was proud to give him every dollar they did. Cheers, Josh Molchan
AI Analysis:
The user's real question is a keyword search for 'injury.' This message discusses a $1.55 million verdict involving a client with mild TBI (traumatic brain injury) symptoms, a fall-related incident, and an elderly plaintiff with dementia/Alzheimer's — all of which relate to injury in a legal/workers' compensation or personal injury context. The message contains substantive discussion of an injury case including the nature of the injury (mild TBI), the circumstances (a fall with no witnesses and no evidence of what caused it), and trial strategy details. However, the message is primarily about trial tactics, judge behavior, and case facts rather than directly explaining or analyzing the concept or legal treatment of 'injury' as a legal term. It is partially relevant as it contains real injury-related case content, but it does not deeply address injury law, definitions, or doctrine.
"Marcy Pettitt" Date: August 05, 2026 8:53:00 PM Subject: Re: $1.55 Million Verdict - Glendale Courthouse Reply to list Reply to sender Print List: caala-workproduct Sent by: Marcy Pettitt (Reply Privately) Search Joshua - congratulations. This is truly awesome. Best, ____________________ Marcy Pettitt, Esq. Partner PETTITT | HOUTZ, PC 1230 Rosecrans Ave., Suite 300 Manhattan Beach, CA 90266 www.pettitthoutz.com 424.241.1010 - office 818.521.6508 - mobile marcy@pettitthoutz.com On Aug 5, 2026, at 6:39 PM, Joshua Molchan (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: Joshua Molchan (Reply Privately) Search All, Following up on Dylan's post below to tell everyone a bit more about the case. - Shorter, Less Expensive Trials - Thoughts From My Recent Trial. The client had felonies, he has gang tattoos on the back of his hands and forearms, he signed and authenticated a release, mild TBI symptoms with a elderly plaintiff with dementia/Alzheimer's, no evidence of how he fell or what he tripped on, no witnesses to the fall, and a conservative jury pool in Glendale. The perfect recipe for a good verdict. We tried the case in front of Judge Ralph Hofer, Department D, Glendale Courthouse. The Defense lawyer was Lorin Snyder who is in-house for Farmer's. He is very nice and easy to work with. Judge Hofer was a bit rusty for a jury trial. We only got 30 minutes for voir dire, no mini opening (does not care about the statute), and he "never" pre-instructs the jury before opening statement. He denied almost every cause challenge on both sides even when they were about as straightforward as they come. Also, he does everything possible for you to settle your case. He dragged us into 5 separate FSCs and each time he would ask us to sit in a conference room with Defense counsel and try to settle the case. He also required both our client and a defense insurance adjuster to personally appear at each Final Status Conference. FACTS 81-year-old Plaintiff was walking down the outside stairs at his second-story apartment when his foot caught on "something" on the second step causing him to fall down the stairs and hit his head at the bottom. He wasn't holding onto the handrail because he had his keys in one hand and his phone in the other. He was not paying attention to the next step. Nobody saw him fall. Nobody knows what he actually tripped on. His wife drove him to the ER where they found a small bump on his forehead but no bleed on the CT scan and sent him home. About three weeks later, Plaintiff told his landlord/defendant about the fall and said he couldn't work full time so he needed $1,500 to cover rent at his auto body shop. The landlord/defendant went and had an attorney draft a release, showed up a week later with a $1,500 check, and told Plaintiff he'd get the money if he signed. Plaintiff didn't read it, didn't have a lawyer look at it, signed his name, and cashed the check. That release obviously turned out to be a huge problem. (We beat a MSJ on it so if you ever run into this issue, I would be happy to share it.) Three weeks after that, Plaintiff 's headaches got much worse and he drove himself back to the ER. This time the imaging showed a moderate acute subdural hematoma and the next day he underwent a right frontal craniotomy to relieve the pressure. Surgery went well. Since then he's just kept up with his neurosurgeon, neurologist, and PCP. Plaintiff's TBI symptoms post incident essentially mirrored someone that was suffering from dementia and early onset Alzheimer's. So much so that his treating neurologist prescribed him medication for early onset dementia to help his memory issues. Plaintiff's complaints at the time of trial were headaches once per month and random instances of forgetfulness. LIABILITY The stairs Plaintiff fell on hadn't been touched since they were built in 1996. A month after the fall, the landlord tore them down and rebuilt them. That left us with nothing but a few photos Plaintiff took a few days after the fall to work with as evidence because Judge Hofer ruled the rebuilt stairs were a subsequent remedial measure and would not budge. He would not even entertain oral arguments or trial briefing on the exceptions. The bigger liability fight was over the release. I have attached the release to this post and encourage you to take a look at it and tell me what your thoughts are because 9/12 jurors thought it meant nothing but 3/12 said it was clear and convincing enough to meet the requirements of a waiver. The Defense told the jury they should award $0 because Plaintiff had signed this release. Both sides had real exposure here. The adjuster seemed to think the release was very clear. It had a title, a date of loss, a short description of the incident, and a 1542 clause, etc. There was definitely enough to lose sleep over. Of course, Gary Dordick was not too concerned with it and saw it as what he calls "Blood in the Water". We used it to tell the full story to the jury. Judge Hofer gave CACI 336 slightly modified on the release issue. We argued for CACI 320 "Interpretation - Construction Against Drafter" but Hofer said no. Question 1 on the verdict form asked the jury whether Plaintiff had waived his right to sue the Defendant. Jurors told us afterward that it was obvious nobody actually understood what they'd signed, so they couldn't call it clear and convincing evidence of a waiver. DAMAGES Plaintiff is now 83 and a lot of his symptoms look almost identical to what you'd see in an average 83-year-old in the early stages of dementia or Alzheimer's. Proving that his cognitive decline traced back to the fall and not just ordinary aging was very difficult especially considering the fact that our client is an old school auto mechanic that didn't complain about anything. This is where Dr. Daniel Franc's testimony came in which was very good. He was able to explain the brain injury to the jury and basically say that in reality, "the lights might be on but nobody is home". Dr. Franc's presentation with the jury and his model brain was very effective. Another issue we had was our jury struggled to understand why a man who had been living independently for three years since his brain surgery suddenly needed millions of dollars in future care. Two jurors told me afterward, almost apologetically, "We thought this type of care was for rich people and not something everyone could afford." The defense went after our experts the way you'd expect. They hit Dr. Franc, our neurologist, for having only physically examined Plaintiff once in person, with every other evaluation done over Zoom. They went after Mark Burns on the theory that his opinions were unreliable because he never personally measured the stairs Plaintiff tripped on. Of course he didn't because the stairs were torn down almost immediately after the fall, before anyone had the chance. Burns's measurements came straight from a handyman's deposition we'd taken a year earlier that did the remodel. We argued to Judge Hofer that by going down this road, defense had opened the door to letting us ask Burns on re-direct why he couldn't measure the stairs. Hofer shut it down right away. Tough ruling to take in the moment but Gary Dordick reminded us afterward you end up thanking the judge for every bad ruling he gives once you get a good verdict because it makes the verdict that much harder to take away from you on appeal. PRE-TRIAL The landlord/defendant carried a $1M underlying policy and a $2M umbrella, both through Farmers. After mediation we came down to $950k and they came up to $525k. A few weeks before trial, we sent a last-chance 998 for $900k. No response. Right before voir dire, they moved to $625k. THE VERDICT As Dylan mentioned above, the first question we got from the jury was a request for a calculator. What he didn't mention was that after the jury's second question (requesting a readback of Dr. Franc's future care recommendations) defense counsel looked over at me and simply said, "Merry Christmas." About an hour after that, three buzzes…we had a verdict. • $719,495.00 - Future Economic Damages • $225,000.00 - Past Non-Economic Damages • $525,000.00 - Future Non-Economic Damages • $80,778.87 - Stipulated Past Medical Specials • $1,550,273.87 - Total Dylan Dordick and I are incredibly fortunate to be able to call our dads before, during, and after trial to share the good, the bad, and the ugly. I want to give a special thank you to our dads, Jeff Molchan and Gary Dordick, for their guidance, "wisdom", and support that contributed to the verdict. At the end of the day, our facts were not great and some of the judges rulings were wrong but our client is a good person that deserved this verdict and I have no doubt the jury was proud to give him every dollar they did. Cheers, Josh Molchan <ClickToViewAttachments-52169095.html>
AI Analysis:
The user's real question is a keyword search for 'injury,' and this message does contain a substantive legal discussion that references injury in a meaningful context. The message addresses a statute of limitations question where the attorney (Michael Avanesian) clarifies that 'the injury is the death not the when he hit his head,' which is a substantive legal point about how 'injury' is defined for SOL purposes in a wrongful death/survival action context. However, the message is extremely brief and lacks depth — it is a one-sentence reply in a thread about CCP 366.1 and statute of limitations, not a focused discussion about the legal definition or significance of 'injury' in workers' compensation or general tort law. The mention of 'injury' is contextually meaningful but the message provides only minimal substantive content. It partially addresses the keyword topic but does not provide a thorough or standalone answer to what someone searching for information about 'injury' would need.
"Michael Avanesian" Date: August 04, 2026 1:06:00 PM Subject: Re: Statute of Limitations Question Reply to list Reply to sender Print Yes, but the injury is the death not the when he hit his head. Sincerely, www.avianlawgroup.com Michael Avanesian, Esq. Chief Executive Officer Licensed to practice in California and Texas Office: 818-282-8400 Fax: 818-688-5161 e: michael@avianlawgroup.com From: Darian Bojeaux (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Monday, August 3, 2026 7:13 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re:[caala-workproduct] Statute of Limitations Question List: caala-workproduct Sent by: Darian Bojeaux (Reply Privately) Search Assuming you quoted the code section correctly, it would be the later date, 2 years after the injury, right? Best, Darian Bojeaux 475 Washington Boulevard Marina del Ray, CA 90292 (310) 270-7221 -----Original Message----- From: dan@attorneymouri.com Sent: July 30, 2026 6:50:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Statute of Limitations Question Hi All: I hope you are doing well. I have a question on a statute of limitations. I have a potential client whose husband fell and struck his head on a private premises because of a dangerous condition on October 19, 2025. He had a major head injury and was in a coma until his death on March 12, 2026. The potential client just came to see me today. I am trying to reconcile California Code, Code of Civil Procedure section 366.1, which says: "If a person entitled to bring an action dies before the expiration of the applicable limitations period, and the cause of action survives, an action may be commenced before the expiration of the later of the following times: (a) Six months after the person's death. (b) The limitations period that would have been applicable if the person had not died." (emphasis added) I have the answer in my head, but just want to confirm I am with everyone else. For a wrongful death lawsuit, what is the statute of limitations date in your opinion? By what date do I have to file suit? Do I have to file six months after the date of the death, which would be on September 12, 2026, or do I have two years from the date of the incident, which would be October 19, 2027? Thanks for the help! Dani Mouri, Esq. HANSON & MOURI 3850 Vine St., Ste. 130 Riverside, CA 92507 (951) 688-0006 Fax: (951) 263-7217 dan@attorneymouri.com < http://attorneymouri.com/ > attorneyhanson.com CONFIDENTIALITY NOTICE: This e-mail, including any attachments, may contain confidential, privileged and/or proprietary information which is solely for the use of the intended recipient(s). Any review, use, disclosure or retention by others is strictly prohibited. If you are not an intended recipient, please contact the sender and delete this e-mail, any attachments and all copies.
AI Analysis:
The user's real question is a keyword search for 'injury,' and this message does contain substantive references to injury — specifically, a major head injury suffered by a premises liability victim who fell and struck his head. The message discusses a statute of limitations question in the context of a personal injury/wrongful death case where the injured party sustained a serious head injury and later died. However, the message does not provide deep substantive analysis about injury itself (e.g., causation, medical evidence, compensability, or injury classification). The word 'injury' appears in context as part of a broader SOL discussion. Since the real question is simply a keyword search for 'injury,' this message is partially relevant in that it contains meaningful factual and legal discussion involving an injury, but it is not a focused analysis of injury law or doctrine.
"Darian Bojeaux" Date: August 03, 2026 9:14:00 PM Subject: Re: Statute of Limitations Question Reply to list Reply to sender Print List: caala-workproduct Sent by: Darian Bojeaux (Reply Privately) Search Assuming you quoted the code section correctly, it would be the later date, 2 years after the injury, right? Best, Darian Bojeaux 475 Washington Boulevard Marina del Ray, CA 90292 (310) 270-7221 -----Original Message----- From: dan@attorneymouri.com Sent: July 30, 2026 6:50:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Statute of Limitations Question Hi All: I hope you are doing well. I have a question on a statute of limitations. I have a potential client whose husband fell and struck his head on a private premises because of a dangerous condition on October 19, 2025. He had a major head injury and was in a coma until his death on March 12, 2026. The potential client just came to see me today. I am trying to reconcile California Code, Code of Civil Procedure section 366.1, which says: "If a person entitled to bring an action dies before the expiration of the applicable limitations period, and the cause of action survives, an action may be commenced before the expiration of the later of the following times: (a) Six months after the person's death. (b) The limitations period that would have been applicable if the person had not died." (emphasis added) I have the answer in my head, but just want to confirm I am with everyone else. For a wrongful death lawsuit, what is the statute of limitations date in your opinion? By what date do I have to file suit? Do I have to file six months after the date of the death, which would be on September 12, 2026, or do I have two years from the date of the incident, which would be October 19, 2027? Thanks for the help! Dani Mouri, Esq. HANSON & MOURI 3850 Vine St., Ste. 130 Riverside, CA 92507 (951) 688-0006 Fax: (951) 263-7217 dan@attorneymouri.com <http://attorneymouri.com/> attorneyhanson.com CONFIDENTIALITY NOTICE: This e-mail, including any attachments, may contain confidential, privileged and/or proprietary information which is solely for the use of the intended recipient(s). Any review, use, disclosure or retention by others is strictly prohibited. If you are not an intended recipient, please contact the sender and delete this e-mail, any attachments and all copies.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message relates to injury in the context of a third-party auto case where multiple injury claims are pending with undetermined values. The subject line references 'injury claims pending,' which directly contains the keyword 'injury.' However, the message body appears to be only a header/forwarding information with no substantive content visible — it is essentially just the subject line and routing metadata. There is no actual discussion or analysis of injury-related legal issues in the body of the message as provided. Given the extremely broad nature of the search (just the keyword 'injury'), the message does mention injury claims, but without substantive content, it only marginally satisfies the search.
From: Richard Weiss (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Sunday, August 2, 2026 2:08 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Question on how to whether a carrier can delay trying to settle a third party auto case that has a value over policy limits if there are other injury claims pending where the value has not yet been determined.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message is from 'Niral Patel Injury Law' and discusses a personal injury/criminal law scenario involving a road rage incident and a potential hit-and-run question. The message does contain the concept of injury (in the firm name and implicitly in the scenario), but it does not substantively answer any specific legal question about injury in a workers' compensation context. The message is primarily a legal question posed to the listserv about hit-and-run liability in a road rage scenario, which is only tangentially related to a general 'injury' keyword search. Given the extremely broad nature of the search ('Looking for keyword: injury'), this message has marginal relevance as it originates from an injury law firm and involves an injury-related incident, but it does not provide substantive information that would help answer a meaningful legal question about injury.
"Niral Patel" Date: August 03, 2026 12:01:00 PM Subject: Is this a Hit and Run? Reply to list Reply to sender Print List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search PC was road raging with another driver in traffic on a three lane road, driving recklessly, flipping fingers, cursing, you name it. PC gestured for the other driver to pull over. PC pulled to the shoulder. Other driver stopped in the #3 lane and boxed PC in, blocking traffic. Predicably, Other driver was rear ended twice. PC, who's vehicle was not impacted, left the scene. Hit and run? Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments.
AI Analysis:
The user's real question is a keyword search for 'injury,' which is an extremely broad and vague query. This message discusses whether a liability insurance carrier can demand a plaintiff's Social Security Number in connection with a personal injury settlement, and cites Smith v. Superior Court regarding the irrelevance of SSN interrogatories. While the word 'injury' appears incidentally in the context of 'personal injury settlements,' the message does not substantively address any specific legal question about injury itself — such as what constitutes a compensable injury, how injuries are evaluated, or any other meaningful legal analysis of the concept of injury in workers' compensation or personal injury law. The message is about SSN disclosure requirements, not about injury as a legal topic. It would not help a reader learn anything meaningful about 'injury' as a subject matter.
"Larry J Easterwood" Date: August 11, 2026 6:41:00 PM Subject: Re: liability carrier demands plaintiff's SSN? Reply to list Reply to sender Print List: caala-workproduct Sent by: Larry Easterwood (Reply Privately) Search Ying See Smith v Superior Court 189 Cal.App.2d 6, 9,13 “16. State all names by which you have been known, the date and place of your birth, your residence, occupation, social security number , height, weight, and the color of your eyes and hair. ( 10 ) Interrogatories 16, 17 and 18 are clearly irrelevant to the subject matter of the action, and the objection on that ground was properly sustained. Larry J Easterwood Esq P O Box 11629 Carson CA 90749-1629 Office 310/532-1624 Cell 310/537-0231 larryjrim@sbcglobal.net From: Ying Xu (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Tuesday, August 11, 2026 12:35 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] liability carrier demands plaintiff's SSN? List: caala-workproduct Sent by: Ying Xu (Reply Privately) Search Mates, I always say No to these requests but wonder what are your best arguments/authorities that could shut them down right away. Is there any clear language in a code, regulation, or case law that says a liability insurance company paying personal injury settlements shall not require the injury claimant's social security number? They all know personal injury compensation is not taxable income, but won't stop asking. Appreciate your thoughts. Ying Ms. Ying Xu, Attorney at Law Law Offices of Eric K Chen 18725 E. Gale Avenue, Suite 228 City of Industry, CA 91748 Tel: 626.810.6163 Fax: 626.810.3732 This email address is used to receive group or subscription emails only. Please reach me at ying@ericchenlaw.com for any other purposes. Thank you This message is intended only for the use of the individual or entity to which it is addressed, and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone. Thank you.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses uninsured/underinsured motorist coverage, release waivers, and the interaction between UM/UIM coverage and workers' compensation reimbursement under California Insurance Code. While the quoted statute mentions 'bodily injury liability insurance' and 'workers' compensation law,' the message does not substantively address any specific legal question about injury in a workers' compensation context. It is focused on UM/UIM release procedures and offset provisions, not on answering any meaningful question about 'injury' as a legal concept or issue. The mere incidental mention of injury-related terms does not make this message responsive to the real question.
barrypkaye@sbcglobal.net Date: August 10, 2026 11:09:00 AM Subject: Re: Underinsured Release Reply to list Reply to sender Print “(h) An insured entitled to recovery under the uninsured motorist endorsement or coverage shall be reimbursed within the conditions stated herein without being required to sign any release or waiver of rights to which he or she may be entitled under any other insurance coverage applicable; nor shall payment under this section to the insured be delayed or made contingent upon the decisions as to liability or distribution of loss costs under other bodily injury liability insurance or any bond applicable to the accident. Any loss payable under the terms of the uninsured motorist endorsement or coverage to or for any person may be reduced: (1) By the amount paid and the present value of all amounts payable to him or her, his or her executor, administrator, heirs, or legal representative under any workers’ compensation law, exclusive of nonoccupational disability benefits. (2) By the amount the insured is entitled to recover from any other person insured under the underlying liability insurance policy of which the uninsured motorist endorsement or coverage is a part, including any amounts tendered to the insured as advance payment on behalf of the other person by the insurer providing the underlying liability insurance.” Barry P. Kaye KAYE LAW OFFICES 10940 Wilshire Boulevard, Suite 1600 Los Angeles, California 90024 T: 310-284-3125 F: 310-284-3126 Email: barrypkaye@sbcglobal.net Web: kayelawoffices.com From: Michael Avanesian (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Sunday, August 9, 2026 7:36 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Underinsured Release List: caala-workproduct Sent by: Michael Avanesian (Reply Privately) Search I would always sign absent some very special circumstances. I also agree, I don’t get why “without” is capitalized but “other” is not. (h) An insured entitled to recovery under the uninsured motorist endorsement or coverage shall be reimbursed within the conditions stated herein WITHOUT being required to sign any release or waiver of rights to which he or she may be entitled under any other insurance coverage applicable Sincerely, www.avianlawgroup.com Michael Avanesian, Esq. Chief Executive Officer Licensed to practice in California and Texas Office: 818-282-8400 Fax: 818-688-5161 e: michael@avianlawgroup.com From: Howard Blumenthal (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Saturday, August 8, 2026 9:48 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Cc: caala-workproduct@lists.trialsmith.com Subject: Re: [caala-workproduct] Underinsured Release List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search Exactly. And my next uim bad faith case will be my first Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059 On Aug 8, 2026, at 3:39 AM, Barry Kaye (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Barry Kaye (Reply Privately) Search That’s the provision I use in refusing to sign. But if you look at it closely, it really doesn’t relive you from that obligation, referring to “ under any other insurance coverage applicable.” National General just tendered for a client and in their voicemail literally said that they ask for the Release, but many attorneys don’t sign it for UIM and it’s not required, but they ask anyway. If they insist, we sign unless you are trying to preserve a bad faith claim. Barry P. Kaye KAYE LAW OFFICES 10940 Wilshire Boulevard, Suite 1600 Los Angeles, California 90024 T: 310-284-3125 F: 310-284-3126 Email: barrypkaye@sbcglobal.net Web: kayelawoffices.com From: Richard Duquette (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Saturday, August 8, 2026 3:18 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Cc: caala-workproduct@lists.trialsmith.com ; caala-workproduct@lists.trialsmith.com Subject: Re: [caala-workproduct] Underinsured Release List: caala-workproduct Sent by: Richard Duquette (Reply Privately) Search See Ca Insurance code section 11580.2 👇 (h) An insured entitled to recovery under the uninsured motorist endorsement or coverage shall be reimbursed within the conditions stated herein WITHOUT being required to sign any release or waiver of rights to which he or she may be entitled under any other insurance coverage applicable; nor shall payment under this section to the insured be delayed or made contingent upon the decisions as to liability or distribution of loss costs under other bodily injury liability insurance or any bond applicable to the accident. Any loss payable under the terms of the uninsured motorist endorsement or coverage to or for any person may be reduced: (1) By the amount paid and the present value of all amounts payable to him or her, his or her executor, administrator, heirs, or legal representative under any workers’ compensation law, exclusive of nonoccupational disability benefits. (2) By the amount the insured is entitled to recover from any other person insured under the underlying liability insurance policy of which the uninsured motorist endorsement or coverage is a part, including any amounts tendered to the insured as advance payment on behalf of the other person by the insurer providing the underlying liability insurance. Richard L. Duquette Attorney at Law Since 1983 Sent from my iPad On Aug 7, 2026, at 7:20 PM, Howard Blumenthal (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search Yes. It is a nothing burger to fight this unless bad faith is alleged Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059 On Aug 7, 2026, at 4:04 PM, Joseph Gallo (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Joseph Gallo (Reply Privately) Search Do you have your clients sign releases for underinsured policy limit settlements? Thank you, Joseph <image001.jpg> Joseph Gallo - Attorney GALLO LAW, APC 4000 MacArthur Blvd., Suite 600 Newport Beach, CA 92660 Tel: (949) 414-5508 | Fax: (949) 203-2166 www.GalloLawGroup.com <image002.png> CONFIDENTIALITY NOTICE: THIS EMAIL, INCLUDING ATTACHMENTS HERETO, IS COVERED BY THE ELECTRONIC COMMUNICATIONS PRIVACY ACT, 18 U.S.C., SECTIONS 2510-2521, AND IS LEGALLY PRIVILEGED. THIS ELECTRONIC MESSAGE IS INTENDED TO BE REVIEWED ONLY BY THE INDIVIDUAL OR ORGANIZATION NAMED ABOVE. UNAUTHORIZED REVIEW, USE, DISCLOSURE OR DISTRIBUTION IS STRICTLY PROHIBITED. THIS EMAIL MAY ALSO BE SUBJECT TO THE ATTORNEY-CLIENT PRIVILEGE OR THE ATTORNEY WORK PRODUCT PRIVILEGE OR BE OTHERWISE CONFIDENTIAL. ANY DISSEMINATION, COPYING OR USE OF THIS EMAIL BY OR TO ANYONE OTHER THAN THE DESIGNATED AND INTENDED RECIPIENT(S) IS UNAUTHORIZED. IF YOU HAVE RECEIVED THIS MESSAGE IN ERROR, PLEASE DELETE IT FROM YOUR SYSTEM IMMEDIATELY AND NOTIFY OUR OFFICE AT ONCE BY TELEPHONE AT (949) 414-5508. THANK YOU FOR YOUR COOPERATION. �
AI Analysis:
The user's real question is a keyword search for 'injury,' but this message is focused on underinsured motorist (UIM) releases, specifically whether an insured must sign a release to receive UIM benefits under California Insurance Code section 11580.2, and practical advice about handling such releases including bad faith claim preservation. While the message incidentally references 'bodily injury liability insurance' in a quoted statute, it does not substantively address or answer any question about 'injury' as a legal topic. The message is about UIM release procedures and insurance code compliance, not about injury law, injury claims, or any injury-related legal question. It only tangentially mentions injury in passing within a statutory quote, which does not make it relevant to a question about injury.
barrypkaye@sbcglobal.net Date: August 08, 2026 5:37:00 AM Subject: Re: Underinsured Release Reply to list Reply to sender Print List: caala-workproduct Sent by: Barry Kaye (Reply Privately) Search That’s the provision I use in refusing to sign. But if you look at it closely, it really doesn’t relive you from that obligation, referring to “ under any other insurance coverage applicable.” National General just tendered for a client and in their voicemail literally said that they ask for the Release, but many attorneys don’t sign it for UIM and it’s not required, but they ask anyway. If they insist, we sign unless you are trying to preserve a bad faith claim. Barry P. Kaye KAYE LAW OFFICES 10940 Wilshire Boulevard, Suite 1600 Los Angeles, California 90024 T: 310-284-3125 F: 310-284-3126 Email: barrypkaye@sbcglobal.net Web: kayelawoffices.com From: Richard Duquette (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Saturday, August 8, 2026 3:18 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Cc: caala-workproduct@lists.trialsmith.com; caala-workproduct@lists.trialsmith.com Subject: Re: [caala-workproduct] Underinsured Release List: caala-workproduct Sent by: Richard Duquette (Reply Privately) Search See Ca Insurance code section 11580.2 👇 (h) An insured entitled to recovery under the uninsured motorist endorsement or coverage shall be reimbursed within the conditions stated herein WITHOUT being required to sign any release or waiver of rights to which he or she may be entitled under any other insurance coverage applicable; nor shall payment under this section to the insured be delayed or made contingent upon the decisions as to liability or distribution of loss costs under other bodily injury liability insurance or any bond applicable to the accident. Any loss payable under the terms of the uninsured motorist endorsement or coverage to or for any person may be reduced: (1) By the amount paid and the present value of all amounts payable to him or her, his or her executor, administrator, heirs, or legal representative under any workers’ compensation law, exclusive of nonoccupational disability benefits. (2) By the amount the insured is entitled to recover from any other person insured under the underlying liability insurance policy of which the uninsured motorist endorsement or coverage is a part, including any amounts tendered to the insured as advance payment on behalf of the other person by the insurer providing the underlying liability insurance. Richard L. Duquette Attorney at Law Since 1983 Sent from my iPad On Aug 7, 2026, at 7:20 PM, Howard Blumenthal (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search Yes. It is a nothing burger to fight this unless bad faith is alleged Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059 On Aug 7, 2026, at 4:04 PM, Joseph Gallo (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Joseph Gallo (Reply Privately) Search Do you have your clients sign releases for underinsured policy limit settlements? Thank you, Joseph <image001.jpg> Joseph Gallo - Attorney GALLO LAW, APC 4000 MacArthur Blvd., Suite 600 Newport Beach, CA 92660 Tel: (949) 414-5508 | Fax: (949) 203-2166 www.GalloLawGroup.com <image002.png> CONFIDENTIALITY NOTICE: THIS EMAIL, INCLUDING ATTACHMENTS HERETO, IS COVERED BY THE ELECTRONIC COMMUNICATIONS PRIVACY ACT, 18 U.S.C., SECTIONS 2510-2521, AND IS LEGALLY PRIVILEGED. THIS ELECTRONIC MESSAGE IS INTENDED TO BE REVIEWED ONLY BY THE INDIVIDUAL OR ORGANIZATION NAMED ABOVE. UNAUTHORIZED REVIEW, USE, DISCLOSURE OR DISTRIBUTION IS STRICTLY PROHIBITED. THIS EMAIL MAY ALSO BE SUBJECT TO THE ATTORNEY-CLIENT PRIVILEGE OR THE ATTORNEY WORK PRODUCT PRIVILEGE OR BE OTHERWISE CONFIDENTIAL. ANY DISSEMINATION, COPYING OR USE OF THIS EMAIL BY OR TO ANYONE OTHER THAN THE DESIGNATED AND INTENDED RECIPIENT(S) IS UNAUTHORIZED. IF YOU HAVE RECEIVED THIS MESSAGE IN ERROR, PLEASE DELETE IT FROM YOUR SYSTEM IMMEDIATELY AND NOTIFY OUR OFFICE AT ONCE BY TELEPHONE AT (949) 414-5508. THANK YOU FOR YOUR COOPERATION. �
AI Analysis:
The user's real question is simply 'Looking for keyword: injury,' which appears to be a broad keyword search rather than a specific legal question. This message discusses motions in limine (MIL) related to a defendant's failure to comply with their own internal safety rules, citing cases about the admissibility of company safety rules as evidence of negligence (Powell, Davis, Dillenbeck, Grudt). While workplace safety rules and negligence are topics that could arise in injury cases, this message does not directly address the concept of 'injury' in any substantive way. The word 'injury' does not appear in this message at all, and the content — focused on evidentiary admissibility of internal corporate rules — does not answer any discernible question about injury. This message appears to be a tangential match at best, with no direct relevance to the real question about injury.
"Greyson Goody" Date: August 06, 2026 2:25:00 PM Subject: Re: MIL Re Defendant's Failure to Comply With Their Own Rules Reply to list Reply to sender Print Attachments: 9. reptile.docx (123 K) List: caala-workproduct Sent by: Greyson Goody (Reply Privately) Search It's buried in this MIL opposition, but here are the cases for you: California courts have long recognized that an employer's or business's safety rules are admissible as evidence bearing on negligence. In Powell v. Pacific Electric Ry. Co. (1950) 35 Cal.2d 40, 46, the California Supreme Court recognized that company rules are admissible as circumstances to be considered in determining negligence. Likewise, in Davis v. Johnson (1954) 128 Cal.App.2d 466, 472, the court held that rules adopted by an employer may be evidence of the standard of care required and of the negligent character of conduct violating those rules. The California Supreme Court later explained that safety rules are probative "as evidence that due care requires the course of conduct prescribed in the rule," because such rules reflect an informed judgment regarding feasible precautions. (Dillenbeck v. City of Los Angeles (1968) 69 Cal.2d 472, 478.) A failure to follow such safety rules may itself constitute evidence of negligence. (Id. at p. 481; Grudt v. City of Los Angeles (1970) 2 Cal.3d 575, 588.) -----Original Message----- From: nkohan@kbtriallawyers.com Sent: August 06, 2026 11:32:00 AM To: caala-workproduct@lists.trialsmith.com Subject: MIL Re Defendant's Failure to Comply With Their Own Rules Defendant Wendys filed a MIL seeking to exclude any evidence that they violated any of their own internal rules or training. Does anyone have an Opposition handy? Thanks in advance. Regards, Nick Nicholas P. Kohan nkohan@kbtriallawyers.com<mailto:nkohan@kbtriallawyers.com> KOHAN & BABLOVE LLP 20371 Irvine Ave., Suite 110 Newport Beach, CA 92660 949.535.1341 (office) 949.629.4486 (direct) 949.303.9427 (mobile) 949.535.1449 (fax)
AI Analysis:
The user's real question is simply 'Looking for keyword: injury,' which appears to be a broad keyword search rather than a specific legal question. This message discusses procedural issues around deposing a Defense Medical Examiner (DME) doctor, citing CCP § 2032.610 and Kennedy v. Superior Court regarding the right to depose an examining physician even after withdrawal as an expert witness. While the message does contain a passing reference to a personal injury action (Kennedy v. Lucky Stores slip and fall), the substantive content of the message is about motion practice related to DME depositions and work product waiver — not about the concept or topic of 'injury' in any meaningful legal sense. The word 'injury' appears only incidentally in a case citation, and this message would not help a reader learn anything substantive about the topic of 'injury' in workers' compensation law. The message is tangentially related at best and does not directly answer or address the real question.
"Greg Jackson" Date: August 05, 2026 9:14:00 AM Subject: Re: Motion to Compel DME Examiners Reply to list Reply to sender Print Attachments: exhibit i.pdf (84 K) exhibit j.pdf (93 K) exhibit k.pdf (71 K) I had to oppose an ex parte on a motion to quash last year when I sought the depo of a DME doc who had given us everything in his report. Here is the relevant excerpt from my opposition, and a few minute orders on this issue. We also served the DME doc with a deposition subpoena to be safe, as defense was playing games. Once Dr. Hill completed his examination of Plaintiff pursuant to California Code of Civil Procedure § 2032.610, “the protection for work product…is waived, both for the examiner’s writings and reports and to the taking of the examiner’s testimony .” (C.C.P. § 2032.610(c) (emphasis added)). California Courts have repeatedly ruled that a party who has submitted to such a physical examination “has the right to depose the examining physician in spite of the fact that the party requesting the examination has withdrawn the physician as an expert witness and redesignated him or her as a ‘consultant.’” ( Kennedy v. Superior Court (1998) 64 Cal.App.4th 674, 676). This is true whether or not the expert has been designated, or withdrawn, and is independent of other timing requirements. In Kennedy , Plaintiff Kennedy filed a personal injury action against Lucky Stores, Inc., after a slip and fall. Lucky Stores demanded Kennedy submit to a medical examination by one Dr. Weil, and Kennedy complied. ( Id. ). Later, Lucky designated Dr. Weil as an expert witness, and then withdrew Dr. Weil as an expert without producing any reports. Kennedy accordingly filed a motion to compel deposition as well as production of the report. The Kennedy Court confirmed the plain meaning of the statute: withdrawing the doctor as an expert does not entitle Lucky “to shield him from deposition” with regard to the examination. ( Id. at 678). The Court went on to state: “A party may “hide” an expert from deposition by withdrawing him and dubbing him a “consultant” thereby reinstating work product protection – but when the expert is also the examining physician per section 2032, the specific terms of the statute must control.” ( Id. at 679). As the Court explicitly stated, the specific terms of §2032.610(c) control and Plaintiff is entitled to Dr. Hill’s deposition testimony. Further, Plaintiff is entitled to call Dr. Hill at trial, regardless of whether Dr. Hill has been designated as an expert or withdrawn. Plaintiff may call Dr. Hill as a witness at trial “free from any restrictions of privilege in [his] examination,” including “[t]he circumstances of [Dr. Hill’s] examination, and of his employment to make that examination…” ( Queen of Angels Hospital v. Superior Court (1976) 57 Cal.App.3d 370, 375). In Queen of Angels , Plaintiff Jones underwent a physical examination by the Defendant’s doctor, Dr. Gabriel. Plaintiff Jones thereafter demanded and received a copy of Dr. Gabriel’s report and deposition. ( Id. at 372). Afterwards, Plaintiff Jones underwent a physical examination by his own expert, Dr. Menkes. Dr. Menkes sent his report to Plaintiff’s counsel, who refused to produce it to Defendants, did not designate Dr. Menkes as an expert, and stated Plaintiff did not intend to call Dr. Menkes as a witness at trial. ( Id. at 373). Defendants filed a motion to compel the report and to permit Defendants to call Dr. Menkes as a witness at trial free from any privilege. The Superior Court denied, and ruled that while Defendants could call Dr. Menkes at trial, they could not question the doctor about his report, his communication with Plaintiff’s counsel, or that he had been employed by Plaintiff’s counsel. ( Id. at 373). The Court of Appeal reversed, finding that the statutory framework is controlling. Plaintiff, by demanding a copy of the Defendants’ expert’s report, fell squarely within California Code of Civil Procedure § 2032.630 and thereby waived any claim of privilege or work product protection for reports, writings, or testimony for any physician who then examined the Plaintiff in turn. ( Id. at 375). The fact that Plaintiff’s counsel did not designate Dr. Menkes and “declared he will not call Dr. Menkes as a witness is of no consequence.” ( Id. ). The reasoning is clear: to conclude otherwise “would permit Jones to arrange unlimited medical examinations and reports and suppress those he might think unfavorable merely by characterizing the doctors who prepared them as advisers to counsel and promising not to call them as witnesses.” ( Id. ). In addition to being entitled to call the doctor at trial, as privilege was waived the doctor could be questioned about “[t]he circumstances of [his] examination, and of his employment to make that examination…” ( Id. ). Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Howard Blumenthal (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Tuesday, August 4, 2026 6:20 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Cc: caala-workproduct@lists.trialsmith.com Subject: Re: [caala-workproduct] Motion to Compel DME Examiners List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search I have never had to use a subpoena send a notice and they must make them appear Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059 On Aug 4, 2026, at 4:26 PM, Shawn Elliott (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Shawn Elliott (Reply Privately) Search If there has been no expert designation, you cannot proceed with the DME doctor's deposition on a notice alone -- you will need to serve a deposition subpoena. Shawn Elliott, Esq. Partner at Lyfe Law T. 888.203.1422 | D. 310.492.7005 | F. 888.203.1424 shawne@lyfe.com 10880 Wilshire Blvd, 24th Fl, Los Angeles CA 90024 www.lyfe.com This message contains information that may be confidential and privileged. Unless you are the addressee (or authorized to receive for the addressee), you are prohibited from using, copying or disclosing, to anyone, this message or any information contained in this message. If you have received this message in error, please contact the sender immediately at (888) 203-1422 and delete all copies of this message. On Tue, Aug 4, 2026 at 4:24 PM Morris Chichyan (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Morris Chichyan (Reply Privately) Search Mates, Blue Hill's counsel, Reisz Siderman Eisenberg, is refusing to allow me to depose their examiners before expert discovery. In several other matters, Blue Hill has never objected to this and I have been able to depose physical examiners pursuant to Kennedy without limitations. At this time, do I have to subpoena the examiners, and then move to compel or can I compel without issuing subpoenas? I have already met and conferred with defense counsel. Any help on this would be greatly appreciated. -- Morris Chichyan, Esq. Managing Attorney CHICHYAN LAW APC 818-488-9448 Morris@chichyanlaw.com www.chichyanlaw.com 400 N Brand Boulevard, Suite 840, Glendale, California 91203 IMPORTANT: The contents of this email and any attachments are confidential. They are intended for the named recipient(s) only. If you have received this email by mistake, please notify the sender immediately and do not disclose the contents to anyone or make copies thereof. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message is a referral thread about orthopedic doctors in Long Beach who work on lien cases. While the word 'injury' appears incidentally (Beau Goodrick asks 'for what type of injury/body part?'), the message does not provide any substantive information that answers a legal question about injury — it is purely a provider referral exchange. There is no legal analysis, statutory interpretation, case strategy, or substantive discussion about the nature, definition, or handling of injuries in workers' compensation law. The mention of 'injury' is purely incidental and contextual, not informative on any legal question related to injury.
barrypkaye@sbcglobal.net Date: August 01, 2026 11:43:00 AM Subject: Re: ORTHO IN LONG BEACH WHO WILL WORK ON LIEN Reply to list Reply to sender Print List: caala-workproduct Sent by: Barry Kaye (Reply Privately) Search https://www.beachcitiesortho.com/ Barry P. Kaye KAYE LAW OFFICES 10940 Wilshire Boulevard, Suite 1600 Los Angeles, California 90024 T: 310-284-3125 F: 310-284-3126 Email: barrypkaye@sbcglobal.net Web: kayelawoffices.com From: Beau Goodrick (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, July 31, 2026 1:42 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re:[caala-workproduct] ORTHO IN LONG BEACH WHO WILL WORK ON LIEN List: caala-workproduct Sent by: Beau Goodrick (Reply Privately) Search For what type of injury/body part? Hamid Mir and Kasra Rowshan are spine orthos that have (or at least had) offices in Long Beach that have been recommended on this listserv and work on lien. Ronna Parsa and Neil Ghodadro are extremity orthos that takes liens with offices in long beach. There are some orthos who specialize in hand/wrist stuff as well among other specialists, but it's unclear what you're looking for. Beau M. Goodrick, Esq. Attorney OWEN, PATTERSON & OWEN, LLP 23822 W. Valencia Blvd, Suite 303 Valencia, California 91355 Office: 661.799.3899 Ext. 777 Fax: 661.799.2774 Website: www.opolaw.com _____________________________________________________________________ The information contained in this e-mail message may be privileged, confidential, and protected from disclosure. If you are not the intended recipient, any further disclosure, use, dissemination, distribution, or copying of this message or any attachment is strictly prohibited. If you think that you have received this e-mail message in error, please delete it and notify the sender.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' While this message does incidentally mention medical injuries (bowel perforation, acute kidney injury, sepsis) in the context of a medical malpractice referral involving a colonoscopy, it does not directly answer or explain anything substantive about 'injury' as a legal concept in workers' compensation. The message is a referral solicitation for a medical malpractice case — it is not a discussion of workers' compensation injury law, injury definitions, injury claims, or any legal analysis related to injury. A reader would not learn anything meaningful about the topic of 'injury' in a workers' compensation legal context from this message. The mention of injury is purely incidental to the medical facts of a malpractice referral, making this message not relevant to the real question.
"Bobbi Bolton" Date: August 06, 2026 6:42:00 PM Subject: Referral - Medical Malpractice - Colonoscopy Reply to list Reply to sender Print List: caala-workproduct Sent by: Bobbi Bolton (Reply Privately) Search Hi Mates, We have a case which we would like to refer. Summary. On 4/8/2026, gastroenterologist attempted a screening colonoscopy at Pasadena Endoscopy Center that had to be aborted - the bowel prep was inadequate and the scope could not be advanced past a severely diverticular sigmoid colon. In his own 4/8 report, Dr. recommended repeating the study "in 1 year," with "extra mag citrate" and a pediatric scope. Instead, he repeated the colonoscopy the very next day, 4/9/2026 - expressly "earlier than the standard recommended time-frame due to inadequate prep." Mr. R perforated in the mid-sigmoid (the same segment documented as impassable), presented the next day with peritonitis and pneumoperitoneum, and underwent emergency robotic washout, abscess drainage, and multi-layer sigmoid repair, followed by a 10-day hospitalization complicated by sepsis/SIRS, ileus, and acute kidney injury. If you are interested, please send an email to chris@pcilc.la Thanks
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses a hit-and-run legal scenario involving road rage and whether a potential client who was not impacted or injured has culpability under hit-and-run statutes. While the word 'injury' appears incidentally (in the attorney's firm name 'Niral Patel Injury Law' and implicitly in the question 'not injured?'), the message does not substantively address, explain, or answer any question about injury in a workers' compensation context. The message is about criminal/traffic law liability (hit-and-run statutes), not about the nature, causation, compensability, or any other substantive aspect of injury. A reader would not learn anything meaningful about 'injury' as a legal concept from this message. It is only tangentially related through keyword overlap in the firm name.
"Niral Patel" Date: August 03, 2026 12:21:00 PM Subject: Re: Is this a Hit and Run? Reply to list Reply to sender Print List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search Correct. He was not impacted. He contributed to the accident by being an idiot, so I'm wondering if he has an culpability under hit and run or similar statutes. -----Original Message----- From: michael@avianlawgroup.com Sent: August 03, 2026 12:13:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Is this a Hit and Run? Your potential client was not hit and is not injured? Sincerely, [cid:image001.png@01DD2330.AB44AD30] www.avianlawgroup.com<http://www.avianlawgroup.com/> Michael Avanesian, Esq. Chief Executive Officer Licensed to practice in California and Texas Office: 818-282-8400 Fax: 818-688-5161 e: michael@avianlawgroup.com<mailto:michael@avianlawgroup.com> From: Niral Patel (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Monday, August 3, 2026 10:01 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Is this a Hit and Run? List: caala-workproduct Sent by: Niral Patel (Reply Privately)<mailto:niralpatel@niralpatelinjurylaw.com?subject=Re%3A%20Is%20this%20a%20Hit%20and%20Run%3F> Search<http://www.caala.org/index.cfm?pg=search> PC was road raging with another driver in traffic on a three lane road, driving recklessly, flipping fingers, cursing, you name it. PC gestured for the other driver to pull over. PC pulled to the shoulder. Other driver stopped in the #3 lane and boxed PC in, blocking traffic. Predicably, Other driver was rear ended twice. PC, who's vehicle was not impacted, left the scene. Hit and run? Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com<mailto:NiralPatel@NiralPatelInjuryLaw.com> Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is a referral recommendation for chiropractic and orthopedic providers in the Ontario/Rancho Cucamonga area who accept liens for an MVA client. While the word 'injury' appears incidentally in the attorney's firm name ('Niral Patel Injury Law'), the message does not substantively address any legal question about injury — such as the nature, causation, compensability, or legal treatment of a workplace or personal injury. The message is essentially a provider referral exchange and does not provide any substantive legal information that would help answer a meaningful question about injury law, injury claims, or injury-related legal issues. It only contains the keyword incidentally as part of a law firm name.
"Niral Patel" Date: August 03, 2026 12:05:00 PM Subject: Re: CHIRO IN Ontario Reply to list Reply to sender Print List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search Cedar Pointe Chiropractic Group and Haven Orthopedic (Rancho Cucamonga) Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. -----Original Message----- From: isaactoveg@aol.com Sent: August 02, 2026 7:23:00 PM To: caala-workproduct@lists.trialsmith.com Subject: CHIRO IN Ontario Client got rear ended in MVA and lives in Ontario. Does anyone have chiro and ortho who will accept liens in Ontario? Thanks, Isaac Toveg Law Office of Isaac Toveg PLC 2600 W. Olive ave., #576 Burbank, CA. 91505 818-333-5202
AI Analysis:
The user's real question is a keyword search for 'injury,' which is an extremely broad query seeking messages that substantively address the topic of injury in a workers' compensation or legal context. This message is a referral request and response regarding a medical malpractice case involving a delayed cancer diagnosis. While the word 'injury' may appear incidentally (e.g., in Bradley Kramer's firm description listing 'Personal Injury' as a practice area), the message does not substantively address, explain, or answer any question about injury in a meaningful legal sense. The content is focused on finding an Armenian-speaking med mal attorney for a specific case — it does not provide legal analysis, case strategy, statutory interpretation, or any other substantive information about injury that would help answer the user's real question.
"Bradley Kramer" Date: August 12, 2026 12:43:00 AM Subject: Re: Looking for Medmal attorney to refer a case - preferably someone who handles cancer related cases Reply to list Reply to sender Print List: caala-workproduct Sent by: Bradley Kramer (Reply Privately) Search Mariam… I am always happy to look at med mal cases, but I do not speak Armenian. If this is a delay in cancer case, there needs to be a significant delay in the diagnosis (usually 8 months or more), AND it needs to have progressed to stage 3 or 4. If that is what happened, I am happy to speak with them. I don’t know anyone on the list serve that does primarily med mal AND speaks Armenian, but I’m sure there’s someone out there. There are some great med mal lawyers on this list serve; but there are also some very shady ones. Happy to share my thoughts offline if you need some advice. BK Best Regards, Bradley I. Kramer, M.D., Esq. biklaw. trial attorneys Medical Malpractice · Personal Injury · Business Litigation 8840 Wilshire Blvd., Suite 350 / Beverly Hills, CA 90211 Tel: (424)-INJURED / (310) 289-2600 / Fax: (866) 289-2771 bkramer@biklaw.com / www.biklaw.com When Having a Great Lawyer Isn't Enough. ® On Jul 30, 2026, at 1:41 PM, Mariam Tsaturyan (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: Mariam Tsaturyan (Reply Privately) Search Good day mates, I have a wonderful lady who came to see me for her husband, who was misdiagnosed/not diagnosed with cancer in a timely manner (MRI report from before clearly showed he had all kind of issues, but radiology either didn't read his report and lied or accidentally read someone else's report and said the husband was ok). I need a good med mal attorney, who either speaks Armenian or has staff who speak Armenian to refer this case to. Thank you.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is a recommendation for an arbitrator in an elder neglect/medical malpractice case. While the underlying case incidentally involves a fall with head injury, the message itself does not provide any substantive legal information about injury — it merely recommends Mark Ratinoff as a plaintiff-friendly arbitrator. The mention of injury is purely incidental to the case description and does not answer any substantive legal question about injury law, injury claims, injury standards, or any related legal doctrine. This is a tangential keyword overlap, not a direct answer to the real question.
"Bradley Kramer" Date: August 11, 2026 11:50:00 PM Subject: Re: Need advice on arbitrator for elder neglect/med mal case Reply to list Reply to sender Print List: caala-workproduct Sent by: Bradley Kramer (Reply Privately) Search Mark Ratinoff is one of my new favorites. He is excellent. Very plaintiff friendly. BK Best Regards, Bradley I. Kramer, M.D., Esq. biklaw. trial attorneys Medical Malpractice · Personal Injury · Business Litigation 8840 Wilshire Blvd., Suite 350 / Beverly Hills, CA 90211 Tel: (424)-INJURED / (310) 289-2600 / Fax: (866) 289-2771 bkramer@biklaw.com / www.biklaw.com When Having a Great Lawyer Isn't Enough. ® On Aug 11, 2026, at 2:51 PM, James Yee (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: James Yee (Reply Privately) Search Hello All, I've been given the option of choosing an arbitrator from the following: Hon. Mark Mooney Sean M. Burke Darrell A. Forgey Any recommendations? The case involves a resident of a skilled nursing facility who was on hospice but also developed worsening pressure sores and suffered a fall with head injury, then passed a way shortly thereafter. The list is not set in stone. Other recommendations are certainly welcome. Thanks in advance.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is from a CAALA (California Applicants' Attorneys Association) listserv, but it is actually from the CAALA Work Product list, not a workers' compensation listserv, and it concerns a request for arbitrator recommendations in an elder neglect/medical malpractice case involving a skilled nursing facility resident. While the message incidentally mentions a 'fall with head injury' as part of the case description, it does not provide any substantive information about injury law, injury claims, injury analysis, or any legal question related to 'injury.' The message is purely about selecting an arbitrator for a specific civil case and does not answer or address any meaningful legal question about injury. The mention of 'injury' is purely incidental to the case description and provides no instructive or analytical value on the topic.
"David Aiso" Date: August 11, 2026 5:30:00 PM Subject: Re: Need advice on arbitrator for elder neglect/med mal case Reply to list Reply to sender Print James, Sean M. Burke David Aiso From: James Yee (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Tuesday, August 11, 2026 2:51 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Need advice on arbitrator for elder neglect/med mal case List: caala-workproduct Sent by: James Yee (Reply Privately) Search Hello All, I've been given the option of choosing an arbitrator from the following: Hon. Mark Mooney Sean M. Burke Darrell A. Forgey Any recommendations? The case involves a resident of a skilled nursing facility who was on hospice but also developed worsening pressure sores and suffered a fall with head injury, then passed a way shortly thereafter. The list is not set in stone. Other recommendations are certainly welcome. Thanks in advance.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' While this message incidentally mentions a 'fall with head injury' as part of a case description in an elder neglect/medical malpractice context, the message itself is not about injury law, injury analysis, or any substantive legal question regarding injuries. The message is entirely focused on recommending arbitrators (Burke vs. Forgey vs. Mooney) for a specific elder neglect/med mal case. The mention of 'head injury' is merely background context for the case type, not substantive information that would help answer any meaningful legal question about injuries. This is a tangential keyword overlap, not a substantive answer to the real question.
eric@trautfirm.com Date: August 11, 2026 4:56:00 PM Subject: Re: Need advice on arbitrator for elder neglect/med mal case Reply to list Reply to sender Print Yes to Burke From: Stuart Berkley (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Tuesday, August 11, 2026 2:54 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Need advice on arbitrator for elder neglect/med mal case List: caala-workproduct Sent by: Stuart Berkley (Reply Privately) Search No on Forgey. STUART BERKLEY 15760 Ventura Boulevard, Suite 700 Encino, CA 91436 (818) 205-1277 (818) 205-1214 (fax) SBerkleyLaw@AOL.com On Tuesday, August 11, 2026 at 02:51:01 PM PDT, CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: James Yee (Reply Privately) Search Hello All, I've been given the option of choosing an arbitrator from the following: Hon. Mark Mooney Sean M. Burke Darrell A. Forgey Any recommendations? The case involves a resident of a skilled nursing facility who was on hospice but also developed worsening pressure sores and suffered a fall with head injury, then passed a way shortly thereafter. The list is not set in stone. Other recommendations are certainly welcome. Thanks in advance.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is from the CAALA Work Product (CAALA) listserv — not the CAAA workers' compensation listserv — and concerns a recommendation for an arbitrator in an elder neglect/medical malpractice case involving a skilled nursing facility resident. While the underlying case incidentally mentions a 'head injury' as part of the factual background, the message does not provide any substantive legal information, analysis, or guidance related to injury law, workers' compensation injury claims, or any other legal topic tied to the concept of 'injury.' The mention of a head injury is purely incidental to the arbitrator recommendation discussion. A reader would not learn anything meaningful about injury law or injury-related legal issues from this message.
"Stuart Berkley" Date: August 11, 2026 4:54:00 PM Subject: Re: Need advice on arbitrator for elder neglect/med mal case Reply to list Reply to sender Print List: caala-workproduct Sent by: Stuart Berkley (Reply Privately) Search No on Forgey. STUART BERKLEY 15760 Ventura Boulevard, Suite 700 Encino, CA 91436 (818) 205-1277 (818) 205-1214 (fax) SBerkleyLaw@AOL.com On Tuesday, August 11, 2026 at 02:51:01 PM PDT, CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: James Yee (Reply Privately) Search Hello All, I've been given the option of choosing an arbitrator from the following: Hon. Mark Mooney Sean M. Burke Darrell A. Forgey Any recommendations? The case involves a resident of a skilled nursing facility who was on hospice but also developed worsening pressure sores and suffered a fall with head injury, then passed a way shortly thereafter. The list is not set in stone. Other recommendations are certainly welcome. Thanks in advance.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' While this message does mention a 'head injury' in passing as part of a case description, the message does not provide any substantive information about injuries in a legal, medical, or workers' compensation context. The message is a request for arbitrator recommendations in an elder neglect/medical malpractice case, and the mention of injury is purely incidental background detail about the underlying facts of that case. A reader would not learn anything meaningful about 'injury' as a legal or factual topic from this message — it is simply seeking arbitrator referrals. The mention of injury is tangential and does not answer or address any substantive question about injury.
"James Yee" Date: August 11, 2026 4:51:00 PM Subject: Need advice on arbitrator for elder neglect/med mal case Reply to list Reply to sender Print List: caala-workproduct Sent by: James Yee (Reply Privately) Search Hello All, I've been given the option of choosing an arbitrator from the following: Hon. Mark Mooney Sean M. Burke Darrell A. Forgey Any recommendations? The case involves a resident of a skilled nursing facility who was on hospice but also developed worsening pressure sores and suffered a fall with head injury, then passed a way shortly thereafter. The list is not set in stone. Other recommendations are certainly welcome. Thanks in advance.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses MV Transportation as a private entity and a potential government tort claim filing, but contains no substantive information about injury — its nature, causation, legal standards, compensability, or any other aspect of injury in a workers' compensation context. The message is a brief procedural note about whether a government tort claim was filed in a specific case, and does not address or answer any meaningful question about injury.
I had a MV Transportation case and it was a private entity. I'll go back and look and see if we did any gov tort claim stuff.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses the procedural question of filing a minor's compromise under seal (referencing CRC 2.551 and 2.550(d)) to protect a minor's identity and medical records in a personal injury case. While the underlying case incidentally involves physical and emotional injuries from a car accident, the message does not substantively address or explain anything about 'injury' as a legal concept, standard, or issue. The message is focused entirely on court filing procedures for protecting a minor's privacy — not on injury law, injury claims, injury standards, or any injury-related legal question. The mere incidental mention of injuries in the background facts does not make this message responsive to the real question.
"Arik Shafir" Date: August 11, 2026 1:41:00 PM Subject: Re: Minor's compromise - can it be filed under Joe Doe? Name redacted in attachments? Reply to list Reply to sender Print You can file the entire thing under seal. See CRC 2.551 for the procedure, and 2.550(d) for the grounds. Arik Shafir SHAFIR LAW, APC 313 North Birch Street, Suite 100 Santa Ana, CA 92701 714.406.2764 voice/text 714.406.2774 fax www.shafirlaw.com STRICTLY CONFIDENTIAL: PRIVILEGED / WORK PRODUCT This email is protected by the E.C.P.A., 18 U.S.C. §§ 2510-2521 and is legally privileged. Confidentiality Note: This e-mail (and any attachments hereto) is intended only for the person or entity to which it is addressed and may contain information that is legally privileged, confidential or otherwise protected from disclosure. Dissemination, distribution or copying of this e-mail or the information contained herein by anyone other than the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, is prohibited. If you have received this e-mail in error or are not the intended recipient, please notify the sender immediately, please delete or destroy the original message and all copies without using, copying or disseminating it. On Aug 11, 2026, at 11:12 AM, Nancy Cole Loeterman (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: My 6 year-old minor client has autism and suffered emotional distress and physical injuries in a car accident. Child’s parents are high net worth. They’re concerned about public nature of Petition for a Minor’s Compromise and attachments, since documents will necessarily refer to medical records that discuss the psychological impact of the accident with the autism overlay. Is it possible to file a Minor’s Compromise with: 1) child as a Doe; and 2) parents as Does? Also, to redact child’s name in the medical records attached to the Petition? Thanks very much. Nancy Mobile: 310-266-4643 Nancy Cole Loeterman Personal Injury Law Cole & Loeterman 1801 Century Park East, Suite 2500 Los Angeles, CA 90067 Office: 310-556-8300 ext. 2 Fax: 310-772-0807 https://www.linkedin.com/in/nancy-cole-loeterman-833704b/ This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged information. If you are not the intended recipient: Any use, copying, disclosure, dissemination or distribution is strictly prohibited; and, please so notify the sender immediately by return e-mail, delete this communication and destroy all copies.
AI Analysis:
The user's real question is simply a keyword search for 'injury,' which is an extremely broad and vague query. This message discusses the allocation of a global settlement between spouses after a wife's death — specifically addressing probate fees, medical bill satisfaction, and tax treatment of personal injury settlements. While the word 'injury' appears incidentally (in 'personal injury is a non-taxable event'), the message does not substantively answer any meaningful question about injury as a legal concept, type, or issue. The message is about estate administration and settlement allocation strategy, not about injury per se. Since the real question is too vague to identify a specific legal issue, and this message only tangentially mentions 'injury' in passing without addressing any coherent question about injury, it should be marked as not relevant.
"Michael Avanesian" Date: August 09, 2026 9:34:00 PM Subject: Re: Allocation of Global Settlement Between Spouses After Wife's Death Reply to list Reply to sender Print At the very least, the amount passed to the husband via probate will be subject to the probate administrator and attorney fees. Also, the wife’s medical bills must be satisfied by what she gets so if there isn’t anything to administer, it is best to allocate as much as you can to husband. Sincerely, www.avianlawgroup.com Michael Avanesian, Esq. Chief Executive Officer Licensed to practice in California and Texas Office: 818-282-8400 Fax: 818-688-5161 e: michael@avianlawgroup.com From: Howard Blumenthal (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, August 7, 2026 7:19 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Cc: caala-workproduct@lists.trialsmith.com Subject: Re: [caala-workproduct] Allocation of Global Settlement Between Spouses After Wife's Death List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search Personal injury is a non-taxable event so I don’t think it matters. It will only matter if the spouse is successor and interest is other than the husband. Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059 On Aug 7, 2026, at 3:54 PM, Anthony Kalikas (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Anthony Kalikas (Reply Privately) Search Mates- I'm looking for guidance on the proper allocation of settlement proceeds in a somewhat unusual situation. I settled a rear-end collision case on behalf of a husband and wife for a single global amount. After the accident, but before mediation, the wife passed away from causes unrelated to the accident. The husband has since been appointed administrator of her estate. My question is whether there is any strategic or legal benefit to allocating a greater percentage of the settlement to the husband's claim versus the wife's claim, assuming the allocation can be reasonably supported by the facts and damages. I'm particularly interested in whether there are any probate, tax, lien, creditor, or other practical considerations that should factor into the allocation. Has anyone dealt with a similar situation? Any authority, practice pointers, or pitfalls to avoid would be greatly appreciated. Thank you in advance.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message is a referral request and attorney response regarding a specific medical malpractice case involving a colonoscopy perforation. While the case involves a physical injury to a patient, the message does not provide any substantive legal analysis, doctrine, or information that would help answer a meaningful question about injury in a workers' compensation or legal context. The message is simply a referral solicitation and attorney advertisement, not a substantive discussion that would help someone learn anything about the legal concept or handling of injury claims. It merely mentions injury incidentally as part of a specific case referral and in the attorney's practice area tagline ('Personal Injury'). This is a tangential keyword overlap, not a direct answer to the real question.
"Bradley Kramer" Date: August 09, 2026 9:26:00 PM Subject: Re: Referral - Medical Malpractice - Colonoscopy Reply to list Reply to sender Print List: caala-workproduct Sent by: Bradley Kramer (Reply Privately) Search Always happy to look at a medical malpractice case. Nearly 100% of my practice is med mal and I am a licensed medical doctor in the state of California. I’ve been doing this work for nearly 2 decades, am an ABOTA member, and am able to handle complex cases big and small as a result of my training and experience. Feel free to call me anytime at 310-289-2600. Thanks! BK Best Regards, Bradley I. Kramer, M.D., Esq. biklaw. trial attorneys Medical Malpractice · Personal Injury · Business Litigation 8840 Wilshire Blvd., Suite 350 / Beverly Hills, CA 90211 Tel: (424)-INJURED / (310) 289-2600 / Fax: (866) 289-2771 bkramer@biklaw.com / www.biklaw.com When Having a Great Lawyer Isn't Enough. ® On Aug 6, 2026, at 4:41 PM, Bobbi Bolton (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: Bobbi Bolton (Reply Privately) Search Hi Mates, We have a case which we would like to refer. Summary. On 4/8/2026, gastroenterologist attempted a screening colonoscopy at Pasadena Endoscopy Center that had to be aborted - the bowel prep was inadequate and the scope could not be advanced past a severely diverticular sigmoid colon. In his own 4/8 report, Dr. recommended repeating the study "in 1 year," with "extra mag citrate" and a pediatric scope. Instead, he repeated the colonoscopy the very next day, 4/9/2026 - expressly "earlier than the standard recommended time-frame due to inadequate prep." Mr. R perforated in the mid-sigmoid (the same segment documented as impassable), presented the next day with peritonitis and pneumoperitoneum, and underwent emergency robotic washout, abscess drainage, and multi-layer sigmoid repair, followed by a 10-day hospitalization complicated by sepsis/SIRS, ileus, and acute kidney injury. If you are interested, please send an email to chris@pcilc.la Thanks
AI Analysis:
This message does not help answer the user's question about 'injury.' The message body appears to be empty or contains no substantive content beyond a quoted header from a forwarded email. There is no discussion of any injury-related legal issue, workers' compensation injury claims, injury definitions, or any other topic related to injury. The subject line references a verdict in San Luis Obispo, but no actual content is present that would address the user's question about injury.
On Aug 9, 2026, at 9:17 AM, Srinivas Hanumadass (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote:
AI Analysis:
The user's real question is simply 'Looking for keyword: injury,' which is too vague to constitute a substantive legal question. However, taking it at face value as a search for messages containing the word 'injury,' this message does tangentially involve physical injury (a TBI and related conditions suffered by a 76-year-old plaintiff in a premises liability case), but it is a civil tort verdict announcement, not a workers' compensation matter. The message is a trial result write-up from a general civil personal injury case in San Luis Obispo Superior Court — not a workers' compensation context. Since this is a CAAA workers' compensation listserv analysis system, and this message does not address any workers' compensation injury question, it does not substantively answer the real question in a meaningful legal research sense. It merely mentions physical injuries in passing as part of a civil verdict announcement.
"Srinivas Hanumadass" Date: August 09, 2026 11:17:00 AM Subject: Verdict in San Luis Obispo! Reply to list Reply to sender Print List: caala-workproduct Sent by: Srinivas Hanumadass (Reply Privately) Search Happy to report a $5,950,000 from my partner Domenic Martini and Ben Koh. Both are not just future stars anymore. They arrived. See Dom's write up below: Good Evening: Happy to report that Ben Koh and I got a $5.975M verdict in Paso Robles, San Luis Obispo Superior Court yesterday. Here's our write up: Facts: 76 year old Mark Nickerson was walking down some stairs in a cabin at an RV park when one of the stairs slid backward off its tracks and sent him falling to the ground. He struck his head and lost consciousness. Screenshot 2026-08-06 at 8.37.45 PM.png Mark suffered a TBI and post-traumatic daily headaches that had characteristics of occipital neuralgia. He declined physically - going from riding Harleys at 76 to needing a walker at 78 (at the time of trial). He underwent about every kind of injection, from botox to ESI to RF ablations and nerve blocks. Trial: Ben and I jumped into this case at the TRC and were brought in by fellow CASD member Andrew Zucker. Shoutout to Andy, who did a fantastic job getting this file teed up for us to come in and take a swing! Defendant's last and best offer was $750,000. Judge Michael Kelley presided over the trial. He bifurcated the trial over our objection but I think in the long run he did us a huge favor. During Phase 1 - We proved the defendant owned the cabin for 9 years and had identical models on their property. On two prior occasions, steps had come loose in other unites and needed to be replaced. After those occasions, defendant did not stop to inspect all the units. The defendant kept no maintenance records and performed no routine inspections. They basically relied on housekeepers to report issues. Defendant had two main points: (1) that our client lied about how this happened and instead just fell down the stairs; and (2) that these cabins are manufactured products and thus this was a products case. Ask me about all the ways they tried to say our client was lying when you see me next. It's too much for this post. But they trotted out two employees who supposedly saw the step in perfect condition while he was being treated by EMTs. We had time stamped photos to disprove their testimony. We got to hit them with their bad incident report and the fact that the employee who "fixed" the step had no memory at all of what it looked like despite remembering the two OSIs with perfect memory. The jury returned a phase 1 verdict of 82.5% liability on the defendant, 17.5% liability on the manufacturer (who was an empty chair defendant) and 0% on our client. We won 10-2. I definitely had some anxiety about the empty chair manufacturer, but my argument that the jury appreciated was that after 9 years, every product breaks down and needs maintenance. Still, they thought the original manufactured screws were too short. Brad Avrit was our expert and while I thought he testified very well, he had an early report that the defense got to use to blame the manufacturer. Phase 2 was fun, because we knew 10 jurors liked us and 2 didn't. That was the beauty of bifurcation. We waived specials and asked for general damages only. The jury liked our client and Paul Jain, MD and Andrew Blumenfeld, MD were fantastic on his TBI and headaches. I think they proved to the jury that this was a debilitating injury. Our case was made much more difficult by the fact that our client was 78, had 3 heart attacks, and two asymptomatic strokes, as well as a long history of orthopedic issues. We also had Dean Dellis on neuropsych but our client's self-reported cognitive issues were not present on any testing. Dellis did a fantastic job explaining how chronic pain causes over-reporting of cognitive defects in patients and in closing I got to explain to the jury that the defects were very real to our client, regardless of what a test says. The defense lined up 3 doctors who all said he was basically faking it, but they ended up nixing one of them and having the other 2 significantly tamp down their opinions-even conceding causation where they originally (kind of) contested it. After phase 1 they didn't want to risk more credibility hits. The jury deliberated for 2 hours and returned a verdict of $975,000 in past and $5,000,000 in future pain and suffering. Trying the case in Paso was fantastic. The jurors were smart and attentive. Judge Kelley was the best trial judge I've ever been in front of. He was fair, kept the jury excited, and let you try the case however you wanted. The wine was great too. Opposing counsel was the Olsen Law group out of Thousand Oaks. Both Joel Witzman and Scott Cox were easy to work with despite their goofy, untenable positions during trial. We got along great off the court. I'm proud of Ben for doing a great job with two openings and a handful of witnesses in his second trial. Most importantly - our client was vindicated. He is a smart, successful former piston engineer for automotive racing with a life and career he is proud of. To be called a liar during the litigation and on the stand was hard for him to deal with. The jury got the truth and let SLO know who the liars were. It was a special moment to him - more meaningful than any of the money. We're proud of this one. Onto the next! -Dom
AI Analysis:
This message does not help answer the user's question about 'injury.' The message body appears to be essentially empty — it contains only a quoted header from a prior email (from Howard Blumenthal, dated Aug 8, 2026) with no substantive content visible. The subject line references 'Underinsured Release,' which relates to insurance settlement topics, not a substantive discussion of injury in the workers' compensation context. There is no information in this message that would help a reader learn anything meaningful about injury as a legal or factual matter.
On Aug 8, 2026, at 12:47 PM, Howard Blumenthal (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote:
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is about whether an attorney should sign an ERISA Notice of Lien from a subrogation company (Intellivo) related to a Kaiser self-funded health benefit plan. While the sender's law firm name happens to include the word 'Injury' (Niral Patel Injury Law), the message itself does not substantively address any legal question about injuries, injury law, injury claims, or injury-related legal standards. The mere incidental appearance of the word 'injury' in the firm name does not make this message relevant to a search for substantive content about injuries. The message's actual subject matter — ERISA lien obligations and whether to sign a subrogation notice — is entirely unrelated to the real question.
"Niral Patel" Date: August 07, 2026 2:42:00 PM Subject: Do I Sign ERISA Notice of Lien? Reply to list Reply to sender Print List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search Client has Kaiser Employee Medical Health Plan, which is a sub-plan under Kaiser Permanente Self-Funded Health Benefit. The subrogation company, Intellivo, sent a "Notice of Lien" for me to sign. Should I sign? This is the language: "By signing below, you are not committing to pay the Plan any amount at the time of settlement; rather, you are merely agreeiug to contact us at the time of settlement, obtain a final lien amount, and hold that amount in your trnst account pending resolution of our claim. Once we receive this letter back signed, we will forward you a detailed itemization of medical expenses and provide updates as requested." Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' While this message subject line mentions 'Very Serious Injuries' in the context of a Utah premises liability case referral, the message body contains no substantive content — it appears to be only a forwarded email header with no actual discussion, analysis, or information about injuries. There is nothing here that would help a reader learn anything meaningful about the topic of injury in a workers' compensation or legal context. The mention of 'injuries' in the subject line is purely incidental and does not provide any substantive answer or insight related to the real question.
From: Eliyahu Ohev Shalom (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, August 7, 2026 10:05 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Utah Attorney needed for a Premises case - Very Serious Injuries
AI Analysis:
The user's real question is a broad keyword search for 'injury,' which is too vague to constitute a specific legal question. This message is a referral solicitation seeking a Utah attorney for a premises liability case involving serious injuries (shoulder surgeries, blindness, deafness, TBI). While the message contains the word 'injuries,' it does not answer any substantive legal question about injury — it is simply a case referral advertisement. It provides no legal analysis, statutory interpretation, procedural guidance, or practical insight that would help answer any meaningful question about injury in the workers' compensation context. The message merely mentions injuries incidentally as part of a business referral posting.
"Eliyahu Ohev Shalom" Date: August 07, 2026 12:06:00 PM Subject: Utah Attorney needed for a Premises case - Very Serious Injuries Reply to list Reply to sender Print List: caala-workproduct Sent by: Eliyahu Ohev Shalom (Reply Privately) Search Lead was injured at work after falling through a skylight that was not up to code. Injuries include: Two shoulder surgeries Blindness in the left eye Deafness in the left ear Level 3 traumatic brain injury Lead is open to being referred out. 1.5.1 fee agreement will be arranged for firms able to sign. Referral fee: 30%. Interested? Email me at eli@limitlesslawllp.com.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is a brief reply from an attorney sharing a motion document (Opposition to Motion in Limine regarding dollar amounts in Voir Dire), with the word 'injury' appearing only incidentally in the sender's professional title ('Employment & Personal Injury'). The message does not substantively address any legal question about injury — it contains no analysis, explanation, or discussion of injury-related law, facts, or strategy. The mention of 'injury' is purely a descriptor of the attorney's practice area in their email signature, not substantive content answering any question about injury. This message would not help a reader learn anything meaningful about the topic of injury in a workers' compensation or legal context.
"Benjamine Sasounian, Esq." Date: August 06, 2026 2:36:00 PM Subject: Re: Motion in Opposition to Defendants MIL to Preclude mention of Dollar Amounts in Voir Dire Reply to list Reply to sender Print Attachments: op.mil.005 (prec. ref. to dollar amts.).docx (53 K) One I’ve filed. Benjamine Sasounian, Esq. LITIGATION ATTORNEY – EMPLOYMENT & PERSONAL INJURY Address 9454 Wilshire Blvd. Suite 830 Beverly Hills, CA 90212 Phone ( 866) 429-4356 Direct (424) 777-0078 , Ext. 1054 TEXT (424) 499-4279 Fax (424) 467-1662 EmaIl benjamine.sasounian@sedlawgroup.com Web www.sedlawgroup.com www.ladylegal.com CONFIDENTIAL EMAIL TRANSMISSION & WARNING: This message and (any attachments hereto) contains confidential information and is intended only for the individual named. It may also be privileged or otherwise protected by work product immunity or other legal rules. If you are not the intended recipient you should not disseminate, distribute, copy this e-mail, or disclose its contents to anyone. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. Any review, use, distribution or disclosure by others is strictly prohibited. The recipient should check this email and any attachments for the presence of viruses. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission, nor does the sender accept liability for damage caused by any virus transmitted by this email. If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised that SEDAGHAT LAW GROUP, APC and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your potential case. ↩ Please Reply All when responding to this email. ♻ Please consider the environment before printing. From: Greyson Goody (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Thursday, August 6, 2026 12:34 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re:[caala-workproduct] Motion in Opposition to Defendants MIL to Preclude mention of Dollar Amounts in Voir Dire List: caala-workproduct Sent by: Greyson Goody (Reply Privately) Search Try this, it should work. -----Original Message----- From: rsflaw2000@yahoo.com Sent: August 03, 2026 11:46:00 AM To: caala-workproduct@lists.trialsmith.com Subject: Re: Motion in Opposition to Defendants MIL to Preclude mention of Dollar Amounts in Voir Dire Eric, The Motion was not attached. Bob On Friday, July 31, 2026 at 12:24:33 PM PDT, Eric Traut (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: ' ' List: caala-workproduct Sent by: Eric Traut (Reply Privately) ' Search ' ' Sending you one I just won last month From: Bob Fink (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Friday, July 31, 2026 12:22 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: [caala-workproduct] Motion in Opposition to Defendants MIL to Preclude mention of Dollar Amounts in Voir Dire ' ' List: caala-workproduct Sent by: Bob Fink (Reply Privately) ' Search ' ' Anyone have an opposition to defendants MIL. Thank you Sending you one I just won last month From: Bob Fink (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Friday, July 31, 2026 12:22 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: [caala-workproduct] Motion in Opposition to Defendants MIL to Preclude mention of Dollar Amounts in Voir Dire ' ' List: caala-workproduct Sent by: Bob Fink (Reply Privately) ' Search ' ' Anyone have an opposition to defendants MIL. Thank you
AI Analysis:
The user's real question is simply 'Looking for keyword: injury,' which appears to be a broad keyword search rather than a specific legal question. This message is a trial report about a $1.55 million premises liability verdict in Glendale involving an elderly plaintiff who fell down stairs and suffered a TBI. While the case inherently involves an injury, this message does not directly answer any specific legal question about injury — it is a case summary discussing trial strategy, judge behavior, jury composition, and verdict details. The message only incidentally involves injury as part of the case facts, without providing substantive legal analysis or guidance on any particular injury-related legal issue. Without a more specific real question about injury law, doctrine, or procedure, this message cannot be deemed directly responsive.
"Joshua Molchan" Date: August 05, 2026 8:40:00 PM Subject: $1.55 Million Verdict - Glendale Courthouse Reply to list Reply to sender Print Attachments: release.pdf (1065 K) List: caala-workproduct Sent by: Joshua Molchan (Reply Privately) Search All, Following up on Dylan's post below to tell everyone a bit more about the case. - Shorter, Less Expensive Trials - Thoughts From My Recent Trial. The client had felonies, he has gang tattoos on the back of his hands and forearms, he signed and authenticated a release, mild TBI symptoms with a elderly plaintiff with dementia/Alzheimer's, no evidence of how he fell or what he tripped on, no witnesses to the fall, and a conservative jury pool in Glendale. The perfect recipe for a good verdict. We tried the case in front of Judge Ralph Hofer, Department D, Glendale Courthouse. The Defense lawyer was Lorin Snyder who is in-house for Farmer's. He is very nice and easy to work with. Judge Hofer was a bit rusty for a jury trial. We only got 30 minutes for voir dire, no mini opening (does not care about the statute), and he "never" pre-instructs the jury before opening statement. He denied almost every cause challenge on both sides even when they were about as straightforward as they come. Also, he does everything possible for you to settle your case. He dragged us into 5 separate FSCs and each time he would ask us to sit in a conference room with Defense counsel and try to settle the case. He also required both our client and a defense insurance adjuster to personally appear at each Final Status Conference. FACTS 81-year-old Plaintiff was walking down the outside stairs at his second-story apartment when his foot caught on "something" on the second step causing him to fall down the stairs and hit his head at the bottom. He wasn't holding onto the handrail because he had his keys in one hand and his phone in the other. He was not paying attention to the next step. Nobody saw him fall. Nobody knows what he actually tripped on. His wife drove him to the ER where they found a small bump on his forehead but no bleed on the CT scan and sent him home. About three weeks later, Plaintiff told his landlord/defendant about the fall and said he couldn't work full time so he needed $1,500 to cover rent at his auto body shop. The landlord/defendant went and had an attorney draft a release, showed up a week later with a $1,500 check, and told Plaintiff he'd get the money if he signed. Plaintiff didn't read it, didn't have a lawyer look at it, signed his name, and cashed the check. That release obviously turned out to be a huge problem. (We beat a MSJ on it so if you ever run into this issue, I would be happy to share it.) Three weeks after that, Plaintiff 's headaches got much worse and he drove himself back to the ER. This time the imaging showed a moderate acute subdural hematoma and the next day he underwent a right frontal craniotomy to relieve the pressure. Surgery went well. Since then he's just kept up with his neurosurgeon, neurologist, and PCP. Plaintiff's TBI symptoms post incident essentially mirrored someone that was suffering from dementia and early onset Alzheimer's. So much so that his treating neurologist prescribed him medication for early onset dementia to help his memory issues. Plaintiff's complaints at the time of trial were headaches once per month and random instances of forgetfulness. LIABILITY The stairs Plaintiff fell on hadn't been touched since they were built in 1996. A month after the fall, the landlord tore them down and rebuilt them. That left us with nothing but a few photos Plaintiff took a few days after the fall to work with as evidence because Judge Hofer ruled the rebuilt stairs were a subsequent remedial measure and would not budge. He would not even entertain oral arguments or trial briefing on the exceptions. The bigger liability fight was over the release. I have attached the release to this post and encourage you to take a look at it and tell me what your thoughts are because 9/12 jurors thought it meant nothing but 3/12 said it was clear and convincing enough to meet the requirements of a waiver. The Defense told the jury they should award $0 because Plaintiff had signed this release. Both sides had real exposure here. The adjuster seemed to think the release was very clear. It had a title, a date of loss, a short description of the incident, and a 1542 clause, etc. There was definitely enough to lose sleep over. Of course, Gary Dordick was not too concerned with it and saw it as what he calls "Blood in the Water". We used it to tell the full story to the jury. Judge Hofer gave CACI 336 slightly modified on the release issue. We argued for CACI 320 "Interpretation - Construction Against Drafter" but Hofer said no. Question 1 on the verdict form asked the jury whether Plaintiff had waived his right to sue the Defendant. Jurors told us afterward that it was obvious nobody actually understood what they'd signed, so they couldn't call it clear and convincing evidence of a waiver. DAMAGES Plaintiff is now 83 and a lot of his symptoms look almost identical to what you'd see in an average 83-year-old in the early stages of dementia or Alzheimer's. Proving that his cognitive decline traced back to the fall and not just ordinary aging was very difficult especially considering the fact that our client is an old school auto mechanic that didn't complain about anything. This is where Dr. Daniel Franc's testimony came in which was very good. He was able to explain the brain injury to the jury and basically say that in reality, "the lights might be on but nobody is home". Dr. Franc's presentation with the jury and his model brain was very effective. Another issue we had was our jury struggled to understand why a man who had been living independently for three years since his brain surgery suddenly needed millions of dollars in future care. Two jurors told me afterward, almost apologetically, "We thought this type of care was for rich people and not something everyone could afford." The defense went after our experts the way you'd expect. They hit Dr. Franc, our neurologist, for having only physically examined Plaintiff once in person, with every other evaluation done over Zoom. They went after Mark Burns on the theory that his opinions were unreliable because he never personally measured the stairs Plaintiff tripped on. Of course he didn't because the stairs were torn down almost immediately after the fall, before anyone had the chance. Burns's measurements came straight from a handyman's deposition we'd taken a year earlier that did the remodel. We argued to Judge Hofer that by going down this road, defense had opened the door to letting us ask Burns on re-direct why he couldn't measure the stairs. Hofer shut it down right away. Tough ruling to take in the moment but Gary Dordick reminded us afterward you end up thanking the judge for every bad ruling he gives once you get a good verdict because it makes the verdict that much harder to take away from you on appeal. PRE-TRIAL The landlord/defendant carried a $1M underlying policy and a $2M umbrella, both through Farmers. After mediation we came down to $950k and they came up to $525k. A few weeks before trial, we sent a last-chance 998 for $900k. No response. Right before voir dire, they moved to $625k. THE VERDICT As Dylan mentioned above, the first question we got from the jury was a request for a calculator. What he didn't mention was that after the jury's second question (requesting a readback of Dr. Franc's future care recommendations) defense counsel looked over at me and simply said, "Merry Christmas." About an hour after that, three buzzes…we had a verdict. • $719,495.00 - Future Economic Damages • $225,000.00 - Past Non-Economic Damages • $525,000.00 - Future Non-Economic Damages • $80,778.87 - Stipulated Past Medical Specials • $1,550,273.87 - Total Dylan Dordick and I are incredibly fortunate to be able to call our dads before, during, and after trial to share the good, the bad, and the ugly. I want to give a special thank you to our dads, Jeff Molchan and Gary Dordick, for their guidance, "wisdom", and support that contributed to the verdict. At the end of the day, our facts were not great and some of the judges rulings were wrong but our client is a good person that deserved this verdict and I have no doubt the jury was proud to give him every dollar they did. Cheers, Josh Molchan
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message is a congratulatory reply about a verdict in a low-impact vehicle collision case, asking to share a closing PowerPoint presentation. While the underlying case context implicitly involves injury (a bus vs. auto collision), this message does not explain, discuss, or answer anything substantive about injury — its nature, causation, legal standards, medical evidence, or any other aspect. It is purely a social/congratulatory exchange with no substantive legal content that would help someone learn anything meaningful about injury in the workers' compensation context. It only tangentially relates to the keyword through the subject matter of the case being referenced.
Congrats. Low impact, limited visible PD cases are some of the hardest. cases to get a mid-6 figure verdict. The defense and insurance industry have the play book down on these cases and they are frequently successful. So getting a W is huge! Can you share your closing powerpoint?
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message is a brief reply ('Exactly what Howard said. EXACTLY. I get these questions all the time.') that contains no substantive information about injury whatsoever. It merely defers to a prior message by 'Howard' without explaining or elaborating on any content related to injury. Even considering the subject line, which references injury claims in the context of a third-party auto case and policy limits, this particular message provides zero substantive information that would help answer any question about injury. It is a non-substantive agreement post with no independent informational value.
Exactly what Howard said. EXACTLY. I get these questions all the time.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses hit-and-run law, specifically whether contact is required to be charged, the definition of 'involved' in an accident under felony and misdemeanor hit-and-run statutes, and law enforcement reporting practices. While a hit-and-run scenario may tangentially involve injury, this message does not directly address, explain, or answer any substantive question about 'injury' in the context of workers' compensation law or any other legal framework. The message only peripherally relates to the concept of injury without providing any substantive information that would help answer a question about injury. It is not relevant.
"traumalaw" Date: August 03, 2026 1:01:00 PM Subject: Re: Is this a Hit and Run? Reply to list Reply to sender Print List: caala-workproduct Sent by: Allen Bell (Reply Privately) Search People are focusing on hit & run and contact. However, you do not have to have contact to be charged. For example if you forced someone off the road or intentionally cut them off during road age and they crashed, you could be charged; failing to render aid / failing to perform a duty. Both felony and misdemeanor H&R speak of being “involved” in an accident. Who knows what the person said to the police regarding what occurred or what witnesses (if any) may have said. Whether law enforcement actually took a H&R report on this is doubtful as most would kiss it off, but you never know. Allen J. Bell, Esq. Law Offices Of Allen Bell & Associates P.O. Box 802555 Santa Clarita, CA 91380 Tel: 818-313-9991 Email: traumalaw@roadrunner.com website: traumalawcenter.net Please note our office hours: Monday – Wednesday: 10:00 a.m. – 3:00 p.m. Thursday: 10:00 a.m. – 1:00 p.m. Closed all Fridays, Saturdays, Sundays and holidays (voicemails, texts and emails not reviewed during closed office hours) This email message contains information that is confidential and privileged. Unless you are the addressee (or authorized to receive messages for the addressee), you may NOT use, copy, or disclose this message or any information contained in it to anyone. If you have received this message in error, please advise the sender by reply email and delete this message. Nothing in this message should be interpreted as a digital or electronic signature that can be used to authenticate a contract or any other legal document. From: Nigel Burns (caala-workproduct listserver) [mailto:listsender-caala-workproduct@lists.trialsmith.com] Sent: Monday, August 03, 2026 10:31 AM To: CAALA Work Product Discussion List Cc: caala-workproduct@lists.trialsmith.com Subject: Re: [caala-workproduct] Is this a Hit and Run? List: caala-workproduct Sent by: Nigel Burns (Reply Privately) Search Luckily, for him, he can’t be prosecuted for being a dickhead. But he might have some exposure for reckless driving. Sent from my iPhone On Aug 3, 2026, at 10:21 AM, Niral Patel (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search Correct. He was not impacted. He contributed to the accident by being an idiot, so I'm wondering if he has an culpability under hit and run or similar statutes. -----Original Message----- From: michael@avianlawgroup.com Sent: August 03, 2026 12:13:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Is this a Hit and Run? Your potential client was not hit and is not injured? Sincerely, [ cid:image001.png@01DD2330.AB44AD30 ] www.avianlawgroup.com<http://www.avianlawgroup.com/ > Michael Avanesian, Esq. Chief Executive Officer Licensed to practice in California and Texas Office: 818-282-8400 Fax: 818-688-5161 e: michael@avianlawgroup.com<mailto:michael@avianlawgroup.com > From: Niral Patel (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Monday, August 3, 2026 10:01 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: [caala-workproduct] Is this a Hit and Run? List: caala-workproduct Sent by: Niral Patel (Reply Privately)< mailto:niralpatel@niralpatelinjurylaw.com?subject=Re%3A%20Is%20this%20a%20Hit%20and%20Run%3F > Search< http://www.caala.org/index.cfm?pg=search > PC was road raging with another driver in traffic on a three lane road, driving recklessly, flipping fingers, cursing, you name it. PC gestured for the other driver to pull over. PC pulled to the shoulder. Other driver stopped in the #3 lane and boxed PC in, blocking traffic. Predicably, Other driver was rear ended twice. PC, who's vehicle was not impacted, left the scene. Hit and run? Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com<mailto:NiralPatel@NiralPatelInjuryLaw.com > Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. This e-mail message has been scanned by Trustwave MailMarshal Cloud Attention: This e-mail is privileged and confidential. If you are not the intended recipient please delete the message and notify the sender. Any views or opinions presented are solely those of the author. Scanned by Trustwave MailMarshal Cloud
AI Analysis:
The user's real question is a keyword search for 'injury.' This message appears to be nearly empty — it contains only a quoted header from a prior email (from Niral Patel) with no substantive content visible. The subject line 'Re: Is this a Hit and Run?' suggests a discussion that could tangentially relate to injury, but there is no actual message body present that addresses any aspect of injury in a workers' compensation context. A reader would learn nothing about injury from this message as presented.
On Aug 3, 2026, at 10:21 AM, Niral Patel (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote:
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses a hit-and-run legal scenario involving road rage and whether a driver who left the scene committed a hit-and-run offense. While the word 'injury' appears incidentally (in the firm name 'Niral Patel Injury Law' and in a clarifying question about whether the potential client was injured), the message does not substantively address any specific legal question about injury — it is focused on hit-and-run liability. The mention of 'injury' is purely incidental and does not provide any substantive information that would help answer a meaningful legal question about injury in the workers' compensation or personal injury context. This is a case of keyword overlap without substantive relevance.
"Michael Avanesian" Date: August 03, 2026 12:13:00 PM Subject: Re: Is this a Hit and Run? Reply to list Reply to sender Print Your potential client was not hit and is not injured? Sincerely, www.avianlawgroup.com Michael Avanesian, Esq. Chief Executive Officer Licensed to practice in California and Texas Office: 818-282-8400 Fax: 818-688-5161 e: michael@avianlawgroup.com From: Niral Patel (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Monday, August 3, 2026 10:01 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Is this a Hit and Run? List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search PC was road raging with another driver in traffic on a three lane road, driving recklessly, flipping fingers, cursing, you name it. PC gestured for the other driver to pull over. PC pulled to the shoulder. Other driver stopped in the #3 lane and boxed PC in, blocking traffic. Predicably, Other driver was rear ended twice. PC, who's vehicle was not impacted, left the scene. Hit and run? Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments.
AI Analysis:
The user's real question is simply looking for content related to 'injury.' This message contains virtually no substantive content — it is only a signature block from Howard S. Blumenthal with contact information. While the subject line references 'injury claims,' the message body itself provides no information, explanation, or discussion that would help answer any question about injury. There is no substantive content to evaluate, making this message not relevant.
Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses litigation strategy for sidewalk trip-and-fall cases against public entities, specifically addressing evidence issues like photos, measurements, and defect descriptions. While a sidewalk trip-and-fall inherently involves an injury, this message does not directly answer any specific question about 'injury' in a workers' compensation context. The message is about premises liability/dangerous condition of public property litigation strategy, not workers' compensation injury law. It only tangentially relates to the concept of injury without addressing any substantive legal question about injury that a workers' compensation attorney would be researching. The content is too general and unrelated to workers' compensation to be considered relevant to a keyword search for 'injury' in this professional legal context.
I don't recall seeing via discovery any photos of sidewalk areas before they were repaired in any of the dozens of bad sidewalk cases that I have handled over the years. I am certain that I have never seen any measurements taken of the dimensions of the defect. Usually, it's just an address and a notation that they were there that day and maybe the times of the start and finish of the repair. In the City of LA, its almost always just asphalt patches and they take less than a hour. I doubt that you can build a case of "dangerous condition" without accurate measurements of an uplift or other defect. A single uplift is usually of varying heights horizontally, some of which may be "trivial", so it is important that your client be able to describe as precisely as possible which foot tripped and where along the uplift that foot was placed. Relying on the public entity having photos and maybe measurements would really be an uphill battle. There are other factors, too, like time of day, visibility of the defect, possible visual obstructions, etc.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses a legal strategy about using evidence of repairs to show ownership or control of a sidewalk — a premises liability or third-party tort concept. While such cases may involve an injury, this message does not explain, define, or address the concept of 'injury' in any substantive way. It merely touches on a tangential procedural tactic in a sidewalk repair case. A reader would not learn anything meaningful about 'injury' from this message.
You can also bring it in to show ownership and or control .
AI Analysis:
The user's real question is a keyword search for 'injury.' This message appears to be about dealing with a repaired sidewalk in the context of a premises liability or civil case (involving a Defendant/City/Private party), which is a CAALA (civil plaintiff attorneys) listserv topic, not a workers' compensation matter. The message body contains no substantive content visible for analysis — it is essentially just a forwarded email header with no actual text addressing any legal question about injury. Even if the topic tangentially relates to physical injury, the message provides no substantive information that would help answer a question about 'injury' in any meaningful legal sense. It is not relevant.
From: Paul Tashnizi (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Saturday, August 1, 2026 2:10 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] How to deal with: Defendant/City/Private party repaired the sidewalk
AI Analysis:
The user's real question is a broad keyword search for 'injury.' While this message does mention the word 'injury' in passing (referring to the risk of injury to others from a dangerous sidewalk condition), it does not substantively answer any meaningful legal question about injury in the workers' compensation context. The message is a brief rhetorical question about the practical tension between notifying a property owner of a dangerous condition and expecting them to preserve it. It touches on premises liability concepts tangentially but provides no substantive legal analysis, case law, statutory interpretation, or practical guidance that would help answer a workers' compensation question about injury. This is merely a keyword overlap — the word 'injury' appears incidentally in a message about a different legal topic (sidewalk defect/spoliation of evidence), not as the subject of any meaningful legal discussion.
Maybe I'm missing something, but how can one notify a property owner/manager that there is a dangerous condition on their property that could cause injury to people and expect them to preserve it (and risk injury to others) for purposes of having an inspection to document the danger?
AI Analysis:
The user's real question is a keyword search for 'injury.' This message discusses a Motion in Limine to exclude duplicative expert testimony (an orthopedic surgeon and neurosurgeon designated by defense on a spine case). While a spine case inherently involves an injury, this message does not discuss, explain, or answer anything substantively about 'injury' as a legal or factual topic. The word 'injury' does not even appear in the message. The message is a request for a legal template (MIL) related to procedural/evidentiary strategy, not a discussion of injury itself. It would not help someone learn anything about the topic of injury in workers' compensation law.
Counsel, Defense has designated an orthopedic surgeon and a neurosurgeon on a purely spine case, and I anticipate the testimony will overlap. Can anyone send me a MIL to exclude duplicative testimony? -- Sincerely, Kenneth R. Shy, Esq. 6700 Fallbrook Ave, Suite 207 • West Hills, CA 91307 Phone: (818) 334-5711 | Fax: (818) 394-6448 | www.mrparkerlaw.com The information contained in or attached to this e-mail is intended only for the use of the named addressee. If you are not an intended recipient of this e-mail, you must not copy, distribute or take any further action in reliance on it and you should delete it and notify the sender immediately. In addition, this e-mail may contain confidential, proprietary or legally privileged information, and a mistransmission of this e-mail is not intended to waive, nor shall it constitute a waiver, of any privilege or confidentiality or proprietary rights NOTICE REGARDING E-SERVICE : All pleadings and time sensitive correspondence must be sent to service@mrparkerlaw.com . M.R. Parker Law P.C. accepts electronic service only at this e-mail address.
AI Analysis:
This message does not help answer the user's question about 'injury.' The message is a request from attorney Kenneth Shy seeking deposition information about four individuals (Dave Atkin, Bruce McCormack, William Hoddick, and Katerina Blazek) designated by Toschi Collins. It contains no substantive information about injury — no legal analysis, case law, statutory interpretation, or practical guidance related to any injury-related topic. The message is purely an administrative/networking request and provides no information that would help someone understand anything about injury in a workers' compensation context.
All designated by Toschi Collins. Anything would be appreciated. -- Sincerely, Kenneth R. Shy, Esq. 6700 Fallbrook Ave, Suite 207 • West Hills, CA 91307 Phone: (818) 334-5711 | Fax: (818) 394-6448 | www.mrparkerlaw.com The information contained in or attached to this e-mail is intended only for the use of the named addressee. If you are not an intended recipient of this e-mail, you must not copy, distribute or take any further action in reliance on it and you should delete it and notify the sender immediately. In addition, this e-mail may contain confidential, proprietary or legally privileged information, and a mistransmission of this e-mail is not intended to waive, nor shall it constitute a waiver, of any privilege or confidentiality or proprietary rights NOTICE REGARDING E-SERVICE : All pleadings and time sensitive correspondence must be sent to service@mrparkerlaw.com . M.R. Parker Law P.C. accepts electronic service only at this e-mail address.
AI Analysis:
The user's real question is a broad keyword search for 'injury.' This message discusses procedural questions about filing a minor's compromise under a pseudonym (Joe Doe), sealing court records, and redacting attachments — referencing CRC 2.551 and 2.550(d). While workers' compensation cases inherently involve injuries, this message does not discuss, explain, or address the concept of 'injury' in any substantive legal sense. The word 'injury' does not even appear in the message. This message is entirely about court filing procedures for minors' compromises and confidentiality, which is tangential to any meaningful question about 'injury.' It would not help a reader learn anything about the topic of injury in a workers' compensation or legal context.
"Aimee Kirby" Date: August 12, 2026 9:59:00 AM Subject: Re: Minor's compromise - can it be filed under Joe Doe? Name redacted in attachments? Reply to list Reply to sender Print List: caala-workproduct Sent by: Aimee Kirby (Reply Privately) Search Yes. We do this often. File the opening complaint with a motion to proceed as Doe. File the Petition redacted and lodge the original with the court, with a motion to seal. You can also use the fact that the settlement is confidential if that helps. -----Original Message----- From: arikshafir@shafirlaw.com Sent: August 11, 2026 1:41:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Minor's compromise - can it be filed under Joe Doe? Name redacted in attachments? You can file the entire thing under seal. See CRC 2.551 for the procedure, and 2.550(d) for the grounds. Arik Shafir SHAFIR LAW, APC 313 North Birch Street, Suite 100 Santa Ana, CA 92701 714.406.2764 voice/text 714.406.2774 fax www.shafirlaw.com<http://www.shafirlaw.com> [cid:A2F75028-A5AD-4E0F-BC7D-65998FC656BF] STRICTLY CONFIDENTIAL: PRIVILEGED / WORK PRODUCT This email is protected by the E.C.P.A., 18 U.S.C. §§ 2510-2521 and is legally privileged. Confidentiality Note: This e-mail (and any attachments hereto) is intended only for the person or entity to which it is addressed and may contain information that is legally privileged, confidential or otherwise protected from disclosure. Dissemination, distribution or copying of this e-mail or the information contained herein by anyone other than the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, is prohibited. If you have received this e-mail in error or are not the intended recipient, please notify the sender immediately, please delete or destroy the original message and all copies without using, copying or disseminating it. [cid:73840D4F-2942-4A3D-915F-3DFEA186D336] On Aug 11, 2026, at 11:12 AM, Nancy Cole Loeterman (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> wrote: My 6 year-old minor client has autism and suffered emotional distress and physical injuries in a car accident. Child's parents are high net worth. They're concerned about public nature of Petition for a Minor's Compromise and attachments, since documents will necessarily refer to medical records that discuss the psychological impact of the accident with the autism overlay. Is it possible to file a Minor's Compromise with: 1) child as a Doe; and 2) parents as Does? Also, to redact child's name in the medical records attached to the Petition? Thanks very much. Nancy Mobile: 310-266-4643 Nancy Cole Loeterman Personal Injury Law Cole & Loeterman 1801 Century Park East, Suite 2500 Los Angeles, CA 90067 Office: 310-556-8300 ext. 2 Fax: 310-772-0807 https://www.linkedin.com/in/nancy-cole-loeterman-833704b/ This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged information. If you are not the intended recipient: Any use, copying, disclosure, dissemination or distribution is strictly prohibited; and, please so notify the sender immediately by return e-mail, delete this communication and destroy all copies.
AI Analysis:
The user's real question is simply 'Looking for keyword: injury,' which appears to be a broad search for messages related to the topic of injury. This message discusses Medicare Secondary Payer compliance, specifically how to handle liability carriers demanding a plaintiff's Social Security Number (SSN) for Medicare reporting purposes. While this topic exists within the broader workers' compensation context, the message does not discuss injury — its nature, causation, treatment, compensability, or any related legal doctrine. The word 'injury' does not appear in the message at all, and the subject matter (SSN disclosure obligations and Medicare repayment consequences) is entirely tangential to any meaningful question about injury. A reader would not learn anything about injury from this message.
If you persist, they always give up. I only went to court on this one time and that was on a post-settlement OSC in Orange County in 2014. (See attached Notice of Ruling). I tell the adjusters that the federal statute requires only that they must ask for the Medicare No. or SSN. Once they get a Section iii. response, their duty is complete. Then, at that point, any consequences for failure to repay Medicare are suffered only by the plaintiff and plaintiff's counsel.
AI Analysis:
This message does not help answer the user's question about 'injury.' The message is a brief, non-substantive reply from Loren Merlin to Sarah, simply thanking her and asking her to check something related to a Commuter Express Bus/MV Transportation case. There is no discussion of injury, injury law, injury claims, or any substantive legal content whatsoever. It is purely a courteous acknowledgment with no informational value relevant to the topic of injury.
Hi Sarah, Thank you. If you could check that would be helpful. Thanks Loren
AI Analysis:
This message does not help answer the user's question about 'injury.' The message is about a liability carrier demanding a plaintiff's SSN and a strategy involving IRS 1099 instructions and 'gross proceeds paid to attorneys.' There is no discussion of injury, injury claims, injury definitions, or any injury-related legal issue. The message is entirely about a tax/identification number disclosure dispute unrelated to the topic of injury.
I'll borrow the "section III exists for a reason" argument and include the IRS 1099 instructions re "gross proceeds paid to attorneys" to see if they'll give up.
AI Analysis:
This message does not help answer the user's real question about 'injury.' The message is about liability carriers demanding a plaintiff's Social Security Number (SSN) and how to decline disclosure using Section III of a CMS form, citing a federal citation. There is no discussion of injury, injury claims, injury causation, injury types, or any related topic that would address the user's question about injury. The message is entirely about SSN disclosure procedures and is not relevant to the real question.
Always fill out and have your client sign Section iii of the CMS form. There would not be a Section iii if declining to disclose a SSN were not permitted. Here are my 2 form responses and the federal citation that allows us to decline to disclose the SSN. (See attachments below)
AI Analysis:
The user's real question is a keyword search for 'injury.' This message discusses bankruptcy proceedings related to 99 Cent Stores and PI (personal injury) cases against bankrupt defendants. While PI cases may tangentially involve injuries, this message does not directly explain, define, or address anything substantive about 'injury' in a workers' compensation or legal context. It is a brief administrative update about the status of a bankruptcy case, with no substantive content about injury law, injury claims, injury definitions, or injury-related legal principles. It does not help a reader learn anything meaningful about the topic of 'injury.'
Not sure about Party City or Forever 21, but the BK of 99 Cent Stores is all but wrapped up. See attached. Shawn Elliott, Esq. Partner at Lyfe Law T. 888.203.1422 | D. 310.492.7005 | F. 888.203.1424 shawne@lyfe.com 10880 Wilshire Blvd, 24th Fl, Los Angeles CA 90024 www.lyfe.com This message contains information that may be confidential and privileged. Unless you are the addressee (or authorized to receive for the addressee), you are prohibited from using, copying or disclosing, to anyone, this message or any information contained in this message. If you have received this message in error, please contact the sender immediately at (888) 203-1422 and delete all copies of this message.
AI Analysis:
This message does not answer the user's question about 'injury.' It is merely an email signature/contact card from Richard A. Harris, a Nevada and California attorney, containing his firm's contact information, office addresses, and credentials. While he is listed as a 'Board Certified Personal Injury Specialist,' the message contains no substantive legal information, analysis, case discussion, or explanation that would help answer any question about injury. There is no meaningful content beyond contact details.
RICHARD A. HARRIS LAWYER - FOUNDING PARTNER DIRECT: 702.444.4424 rick@harris.legal Admitted in Nevada and California Board Certified Personal Injury Specialist - Nevada Lifetime Achievement Award - Nevada Justice Association 801 S. 4th Street, Las Vegas NV 89101 6900 S. McCarran Blvd., #1010, Reno NV 89509 702.444.4444 - Las Vegas 775.222.2222 - Reno 833.222.2222 - Toll Free 702.444.4455 - Fax WHAT'S YOUR STORY? HERE'S OURS . Please read the Legal Disclaimer that governs this email and any attachments.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message does not substantively address any legal question about injury — it is simply a referral recommendation for a dentist willing to work on a lien in Los Angeles. The word 'injury' appears only incidentally in the sender's law firm name ('Niral Patel Injury Law') as part of a signature block, not in any substantive legal context. A reader would learn nothing about the topic of injury from this message. It is not relevant to any meaningful legal question about injury in workers' compensation law.
"Niral Patel" Date: August 10, 2026 3:46:00 PM Subject: Re: Dentist on a Lien Reply to list Reply to sender Print List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search Try Dr. Dan Benyamini in Beverly Hills at (424) 396-6785 Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. -----Original Message----- From: ritsa.gountoumas@gatelegal.com Sent: August 10, 2026 3:31:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Dentist on a Lien Hello, does anyone have recommendations for a dentist on a lien in Los Angeles? *Ritsa Gountoumas ' Attorney ' Golden Gate Legal LLP* 7060 Hollywood Blvd, Suite 530'Los Angeles, CA 90028 Direct: 310-445-3425 ' Fax: 310-928-1341 *ritsa.gountoumas@gatelegal.com <ritsa.gountoumas@gatelegal.com>* *www.gatelegal.com <http://www.gatelegal.com/>* The information contained in this e-mail message is intended only for the CONFIDENTIAL use of the designated addressee named above. The information transmitted is subject to the attorney-client privilege and/or represents confidential attorney work product. Recipients should not file copies of this email with publicly accessible records. If you are not the designated addressee named above or the authorized agent responsible for delivering it to the designated addressee, you received this document through inadvertent error and any further review, dissemination, distribution or copying of this communication by you or anyone else is strictly prohibited. IF YOU RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONING THE SENDER NAMED ABOVE AT 310.445.3425. Thank you.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is about a client refusing to cash a settlement check and the attorney's concern about handling such situations. The word 'injury' appears only incidentally as part of the law firm's name ('Niral Patel Injury Law') in the email signature — it is not substantively discussed in the message content. The message does not address any legal question, concept, or topic related to 'injury' in a workers' compensation or legal context. A reader would learn nothing about 'injury' as a substantive topic from this message.
"Niral Patel" Date: August 10, 2026 3:44:00 PM Subject: Re: Client refusing to cash settlement check. Reply to list Reply to sender Print List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search I think handing a seemingly troubled or indigent client a cashier's check is playing with fire. Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. -----Original Message----- From: jlg@gordon.law Sent: August 10, 2026 3:30:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Client refusing to cash settlement check. Have a case that settled several months ago. Case disbursed, but client is refusing to cash the check. He initially sent text messages saying he would cash it etc. Now he is just ghosting me. Without knowing what his motives are, I need the money in his account and out of my trust. What is the best way to effectuate this? I was thinking of stopping payment on the check and having a bank draft / cashier's check hand delivered to him. Regards, Justin L. Gordon, JD, LLM* LAW OFFICES OF JUSTIN L. GORDON 21300 Victory Boulevard, Suite 300 Woodland Hills, California 91367 Telephone: (818) 710-2730 Text Message: (818) 293-7178 Facsimile: (818) 276-8367 Website: plaintiff.law Confidentiality Notice: This e-mail and its contents contain confidential and/or privileged attorney-client communications. If you are not the intended recipient of this e-mail, please notify the sender and delete the message. * Licensed in California, Texas, and the District of Columbia; admitted to practice before all United States District Courts in California, the United States Court of Appeals for the Fifth and Ninth Circuits, and the Supreme Court of the United States.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message does not address the topic of injury in any substantive way. It is a discussion about whether attorneys should sign a release or waiver in the context of underinsured motorist (UIM) coverage, referencing an insurance code provision about uninsured motorist endorsements. While workers' compensation and UIM cases can involve injuries, this message contains no information that would help answer any question about 'injury' as a legal concept, standard, or issue. The word 'injury' does not even appear in the message. This is entirely about UIM release-signing practice and a statutory interpretation of an insurance provision, which is tangential at best to any question about injury.
"Michael Avanesian" Date: August 09, 2026 9:36:00 PM Subject: Re: Underinsured Release Reply to list Reply to sender Print I would always sign absent some very special circumstances. I also agree, I don’t get why “without” is capitalized but “other” is not. (h) An insured entitled to recovery under the uninsured motorist endorsement or coverage shall be reimbursed within the conditions stated herein WITHOUT being required to sign any release or waiver of rights to which he or she may be entitled under any other insurance coverage applicable Sincerely, www.avianlawgroup.com Michael Avanesian, Esq. Chief Executive Officer Licensed to practice in California and Texas Office: 818-282-8400 Fax: 818-688-5161 e: michael@avianlawgroup.com From: Howard Blumenthal (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Saturday, August 8, 2026 9:48 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Cc: caala-workproduct@lists.trialsmith.com Subject: Re: [caala-workproduct] Underinsured Release List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search Exactly. And my next uim bad faith case will be my first Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059 On Aug 8, 2026, at 3:39 AM, Barry Kaye (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Barry Kaye (Reply Privately) Search That’s the provision I use in refusing to sign. But if you look at it closely, it really doesn’t relive you from that obligation, referring to “ under any other insurance coverage applicable.” National General just tendered for a client and in their voicemail literally said that they ask for the Release, but many attorneys don’t sign it for UIM and it’s not required, but they ask anyway. If they insist, we sign unless you are trying to preserve a bad faith claim. Barry P. Kaye KAYE LAW OFFICES 10940 Wilshire Boulevard, Suite 1600 Los Angeles, California 90024 T: 310-284-3125 F: 310-284-3126 Email: barrypkaye@sbcglobal.net Web: kayelawoffices.com From: Richard Duquette (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Saturday, August 8, 2026 3:18 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Cc: caala-workproduct@lists.trialsmith.com ; caala-workproduct@lists.trialsmith.com Subject: Re: [caala-workproduct] Underinsured Release List: caala-workproduct Sent by: Richard Duquette (Reply Privately) Search See Ca Insurance code section 11580.2 👇 (h) An insured entitled to recovery under the uninsured motorist endorsement or coverage shall be reimbursed within the conditions stated herein WITHOUT being required to sign any release or waiver of rights to which he or she may be entitled under any other insurance coverage applicable; nor shall payment under this section to the insured be delayed or made contingent upon the decisions as to liability or distribution of loss costs under other bodily injury liability insurance or any bond applicable to the accident. Any loss payable under the terms of the uninsured motorist endorsement or coverage to or for any person may be reduced: (1) By the amount paid and the present value of all amounts payable to him or her, his or her executor, administrator, heirs, or legal representative under any workers’ compensation law, exclusive of nonoccupational disability benefits. (2) By the amount the insured is entitled to recover from any other person insured under the underlying liability insurance policy of which the uninsured motorist endorsement or coverage is a part, including any amounts tendered to the insured as advance payment on behalf of the other person by the insurer providing the underlying liability insurance. Richard L. Duquette Attorney at Law Since 1983 Sent from my iPad On Aug 7, 2026, at 7:20 PM, Howard Blumenthal (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search Yes. It is a nothing burger to fight this unless bad faith is alleged Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059 On Aug 7, 2026, at 4:04 PM, Joseph Gallo (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Joseph Gallo (Reply Privately) Search Do you have your clients sign releases for underinsured policy limit settlements? Thank you, Joseph <image001.jpg> Joseph Gallo - Attorney GALLO LAW, APC 4000 MacArthur Blvd., Suite 600 Newport Beach, CA 92660 Tel: (949) 414-5508 | Fax: (949) 203-2166 www.GalloLawGroup.com <image002.png> CONFIDENTIALITY NOTICE: THIS EMAIL, INCLUDING ATTACHMENTS HERETO, IS COVERED BY THE ELECTRONIC COMMUNICATIONS PRIVACY ACT, 18 U.S.C., SECTIONS 2510-2521, AND IS LEGALLY PRIVILEGED. THIS ELECTRONIC MESSAGE IS INTENDED TO BE REVIEWED ONLY BY THE INDIVIDUAL OR ORGANIZATION NAMED ABOVE. UNAUTHORIZED REVIEW, USE, DISCLOSURE OR DISTRIBUTION IS STRICTLY PROHIBITED. THIS EMAIL MAY ALSO BE SUBJECT TO THE ATTORNEY-CLIENT PRIVILEGE OR THE ATTORNEY WORK PRODUCT PRIVILEGE OR BE OTHERWISE CONFIDENTIAL. ANY DISSEMINATION, COPYING OR USE OF THIS EMAIL BY OR TO ANYONE OTHER THAN THE DESIGNATED AND INTENDED RECIPIENT(S) IS UNAUTHORIZED. IF YOU HAVE RECEIVED THIS MESSAGE IN ERROR, PLEASE DELETE IT FROM YOUR SYSTEM IMMEDIATELY AND NOTIFY OUR OFFICE AT ONCE BY TELEPHONE AT (949) 414-5508. THANK YOU FOR YOUR COOPERATION. �
AI Analysis:
The user's real question is a keyword search for 'injury.' This message discusses underinsured motorist (UIM) releases — specifically whether attorneys are required to sign a release when a UIM carrier tenders payment, referencing California Insurance Code section 11580.2 and strategies around preserving bad faith claims. While UIM cases often arise from injuries, this message does not discuss injury in any substantive way. It does not explain, define, or address injury-related legal concepts, standards, or issues. The word 'injury' does not even appear in the message. This message is entirely about UIM release procedures and bad faith preservation strategy, making it not relevant to a search focused on 'injury.'
Ditto what Brother Howard said. Technically, a release is not required, but it makes life easier for a lot of adjusters and they are grateful for it. Sent from my iPhone On Aug 8, 2026, at 12:47 PM, Howard Blumenthal (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search Exactly. And my next uim bad faith case will be my first Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059 On Aug 8, 2026, at 3:39 AM, Barry Kaye (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: Barry Kaye (Reply Privately) Search That’s the provision I use in refusing to sign. But if you look at it closely, it really doesn’t relive you from that obligation, referring to “ under any other insurance coverage applicable.” National General just tendered for a client and in their voicemail literally said that they ask for the Release, but many attorneys don’t sign it for UIM and it’s not required, but they ask anyway. If they insist, we sign unless you are trying to preserve a bad faith claim. Barry P. Kaye KAYE LAW OFFICES 10940 Wilshire Boulevard, Suite 1600 Los Angeles, California 90024 T: 310-284-3125 F: 310-284-3126 Email: barrypkaye@sbcglobal.net Web: kayelawoffices.com From: Richard Duquette (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Saturday, August 8, 2026 3:18 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Cc: caala-workproduct@lists.trialsmith.com; caala-workproduct@lists.trialsmith.com Subject: Re: [caala-workproduct] Underinsured Release List: caala-workproduct Sent by: Richard Duquette (Reply Privately) Search See Ca Insurance code section 11580.2 👇 (h) An insured entitled to recovery under the uninsured motorist endorsement or coverage shall be reimbursed within the conditions stated herein WITHOUT being required to sign any release or waiver of rights to which he or she may be entitled under any other insurance coverage applicable; nor shall payment under this section to the insured be delayed or made contingent upon the decisions as to liability or distribution of loss costs under other bodily injury liability insurance or any bond applicable to the accident. Any loss payable under the terms of the uninsured motorist endorsement or coverage to or for any person may be reduced: (1) By the amount paid and the present value of all amounts payable to him or her, his or her executor, administrator, heirs, or legal representative under any workers’ compensation law, exclusive of nonoccupational disability benefits. (2) By the amount the insured is entitled to recover from any other person insured under the underlying liability insurance policy of which the uninsured motorist endorsement or coverage is a part, including any amounts tendered to the insured as advance payment on behalf of the other person by the insurer providing the underlying liability insurance. Richard L. Duquette Attorney at Law Since 1983 Sent from my iPad On Aug 7, 2026, at 7:20 PM, Howard Blumenthal (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search Yes. It is a nothing burger to fight this unless bad faith is alleged Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059 On Aug 7, 2026, at 4:04 PM, Joseph Gallo (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Joseph Gallo (Reply Privately) Search Do you have your clients sign releases for underinsured policy limit settlements? Thank you, Joseph <image001.jpg> Joseph Gallo - Attorney GALLO LAW, APC 4000 MacArthur Blvd., Suite 600 Newport Beach, CA 92660 Tel: (949) 414-5508 | Fax: (949) 203-2166 www.GalloLawGroup.com <image002.png> CONFIDENTIALITY NOTICE: THIS EMAIL, INCLUDING ATTACHMENTS HERETO, IS COVERED BY THE ELECTRONIC COMMUNICATIONS PRIVACY ACT, 18 U.S.C., SECTIONS 2510-2521, AND IS LEGALLY PRIVILEGED. THIS ELECTRONIC MESSAGE IS INTENDED TO BE REVIEWED ONLY BY THE INDIVIDUAL OR ORGANIZATION NAMED ABOVE. UNAUTHORIZED REVIEW, USE, DISCLOSURE OR DISTRIBUTION IS STRICTLY PROHIBITED. THIS EMAIL MAY ALSO BE SUBJECT TO THE ATTORNEY-CLIENT PRIVILEGE OR THE ATTORNEY WORK PRODUCT PRIVILEGE OR BE OTHERWISE CONFIDENTIAL. ANY DISSEMINATION, COPYING OR USE OF THIS EMAIL BY OR TO ANYONE OTHER THAN THE DESIGNATED AND INTENDED RECIPIENT(S) IS UNAUTHORIZED. IF YOU HAVE RECEIVED THIS MESSAGE IN ERROR, PLEASE DELETE IT FROM YOUR SYSTEM IMMEDIATELY AND NOTIFY OUR OFFICE AT ONCE BY TELEPHONE AT (949) 414-5508. THANK YOU FOR YOUR COOPERATION. �
AI Analysis:
This message does not help answer the user's question about 'injury.' The message contains only a signature block from Howard S. Blumenthal, Esq., with contact information (phone, fax numbers) and a subject line referencing 'Underinsured Release.' There is no substantive content, discussion, or information about injury of any kind. A reader would learn nothing about injury from this message.
Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059
AI Analysis:
This message does not help answer the user's question about 'injury.' The message contains only a signature block from Howard S. Blumenthal, Esq., with contact information (phone, fax numbers) and a subject line referencing 'Underinsured Release.' There is no substantive content, discussion, or information about injury of any kind. The message body is essentially empty of legal analysis or discussion that would address the user's question.
Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059
AI Analysis:
The user's real question is a keyword search for 'injury.' This message contains virtually no substantive content — it is merely a signature block identifying Richard L. Duquette as an attorney since 1983, sent from an iPad, in reply to a thread about 'Underinsured Release.' There is no discussion of injury, no legal analysis, no facts, and no information that would help answer any question related to injury in a workers' compensation context. The message body is essentially empty of informational content.
Richard L. Duquette Attorney at Law Since 1983 Sent from my iPad
AI Analysis:
The user's real question is a keyword search for 'injury.' This message contains only a signature block from Howard S. Blumenthal, Esq., with contact information (phone, fax numbers). There is no substantive content whatsoever — no discussion of injury, workers' compensation law, case strategy, or any legal topic. The subject line references 'Allocation of Global Settlement Between Spouses After Wife's Death,' which is tangentially related to workers' compensation but does not address the topic of injury. This message provides no information that would help answer any question about injury.
Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is a brief reply thread about a $1.55 million verdict at the Glendale Courthouse, with attorneys requesting to share an opposition to a motion for summary judgment regarding a release and a list of experts. The message contains no substantive discussion of 'injury' — the word does not even appear in the message. The content is entirely about sharing case documents and congratulating a colleague on a verdict. It does not explain, define, or address anything related to injury in a legal or workers' compensation context. This message is not relevant to the user's search.
"Christopher Gansen" Date: August 07, 2026 2:33:00 PM Subject: Re: $1.55 Million Verdict - Glendale Courthouse Reply to list Reply to sender Print List: caala-workproduct Sent by: Christopher Gansen (Reply Privately) Search Yes, and a list of experts? -----Original Message----- From: mlorenesq@gmail.com Sent: August 07, 2026 2:29:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: $1.55 Million Verdict - Glendale Courthouse Congrats!! Can you share the opp to the MSJ regarding the release. Thanks Loren On Fri, Aug 7, 2026 at 8:37 AM James Dicks (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* James Dicks (Reply Privately) > <jim@jdlaw.law?subject=Re%3A%20%5Bcaala-workproduct%5D%20%241.55%20Million%20Verdict%20-%20Glendale%20Courthouse> > Search <http://www.caala.org/index.cfm?pg=search> > Can some please er send Dylan's original post ,/ > > > Kind Regards, > [image: photo] > > James Dicks > Certified Criminal Law Specialist ' California Board of Legal > Specialization, jD Law > > [image: facebook] <https://www.facebook.com/JDLawDefense> > > [image: instagram] <https://www.instagram.com/jd_law_office/?hl=en> > > [image: linkedin] <https://www.linkedin.com/in/james-dicks-14346118/> > > [image: tiktok] <https://www.tiktok.com/@jd.laww?_t=ZT-90jw3vrAi33&_r=1> > > [image: custom_u/VkGX9yAjGp3/ee20ec72-701d-4a13-969d-a0cba3440c4d__45x45__] > <https://digital.modernluxury.com/publication/?i=852880&p=89&pp=1&view=issueViewer> > > [image: icon] (760) 630-2000 <(760)630-2000> [image: icon] (760)630-2002 > [image: icon] jdlaw.law > > [image: icon] jim@jdlaw.law > > [image: icon] 400 S. Melrose Dr Suite 109, Vista, CA 92081 > <https://maps.google.com/?q=400%20S.%20Melrose%20Dr%20Suite%20109,%20Vista,%20CA%2092081> > > > PLEASE ALLOW 24-48 BUSINESS HOURS FOR A RESPONSE > > This e-mail message is only intended for the person(s) to whom it > is addressed. It may contain confidential and proprietary information and > is protected from disclosure. If you are not the intended recipient or a > person responsible for delivering it to the intended recipient, you are > hereby notified that any review, retention, copying or distribution of > this communication is prohibited by law. Please reply to the sender that > you have received the message in error, and then delete it. In addition, > please be aware that any message addressed to our company is subject to > archiving and review by persons other than the intended recipient. Although > reasonable precautions have been taken to ensure that no viruses or other > harm are present, jD LAW make no warranty or guaranty with respect to, and > are not responsible for any loss or damage arising from the receipt or use > of this e-mail or attachments. Thank you. > > On Aug 6, 2026, at 7:21 PM, Ron A. Rosen Janfaza (caala-workproduct > listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > > *List:* caala-workproduct *Sent by:* Ron A. Rosen Janfaza (Reply > Privately) > <janfazalaw1@yahoo.com?subject=Re%3A%20%5Bcaala-workproduct%5D%20%241.55%20Million%20Verdict%20-%20Glendale%20Courthouse> > Search <http://www.caala.org/index.cfm?pg=search> > Mates: > > Wow this is great! I was unaware that you could get around a Release that > way. Sounds like amazing results for this type of case. Appreciate the > details of the case. Mazal tov! Talk soon! > > Sincerely, > > > > Ron A. Rosen Janfaza, Esq. > Telephone: (310) 550-1000 > CAALA e-mail: janfazalaw1@yahoo.com > > PLEASE BE ADVISED THAT THE DOCUMENTS AND INFORMATION CONTAINED IN THIS > E-MAIL (INCLUDING ALL E-MAIL COVER SHEETS) CONTAIN INFORMATION BELONGING TO > THE SENDER THAT IS CONFIDENTIAL, PRIVILEGED AND EXEMPT FROM DISCLOSURE > UNDER APPLICABLE LAW. THE DOCUMENTS AND INFORMATION CONTAINED IN THIS > E-MAIL ARE INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH > IT IS ADDRESSED. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED > RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISCLOSURE OR > COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY THIS OFFICE > IMMEDIATELY IF YOU HAVE RECEIVED THIS E-MAIL IN ERROR AND RETURN THE ENTIRE > CONTENTS TO THE ABOVE NOTED E-MAIL ADDRESS. > > > > On Thursday, August 6, 2026 at 08:28:58 AM PDT, Eric Valenzuela > (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com> wrote: > > > *List:* caala-workproduct *Sent by:* Eric Valenzuela (Reply Privately) > <evalenzuela@galipolaw.com?subject=Re%3A%20%5Bcaala-workproduct%5D%20%241.55%20Million%20Verdict%20-%20Glendale%20Courthouse> > Search <http://www.caala.org/index.cfm?pg=search> > Amazing result great job and awesome write up!!! > > > *From:* Joshua Molchan (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com> > *Sent:* Wednesday, August 5, 2026 6:39 PM > *To:* CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com> > *Subject:* [caala-workproduct] $1.55 Million Verdict - Glendale Courthouse > > > > > *List:* caala-workproduct *Sent by:* Joshua Molchan (Reply Privately) > <josh.molchan@dordicklaw.com?subject=Re%3A%20%241.55%20Million%20Verdict%20-%20Glendale%20Courthouse> > *Search* <http://www.caala.org/index.cfm?pg=search> > > All, > > Following up on Dylan's post below to tell everyone a bit more about the > case. - Shorter, Less Expensive Trials - Thoughts From My Recent Trial. > > The client had felonies, he has gang tattoos on the back of his hands and > forearms, he signed and authenticated a release, mild TBI symptoms with a > elderly plaintiff with dementia/Alzheimer's, no evidence of how he fell or > what he tripped on, no witnesses to the fall, and a conservative jury pool > in Glendale. The perfect recipe for a good verdict. > > We tried the case in front of Judge Ralph Hofer, Department D, Glendale > Courthouse. The Defense lawyer was Lorin Snyder who is in-house for > Farmer's. He is very nice and easy to work with. > > Judge Hofer was a bit rusty for a jury trial. We only got 30 minutes for > voir dire, no mini opening (does not care about the statute), and he > "never" pre-instructs the jury before opening statement. He denied almost > every cause challenge on both sides even when they were about as > straightforward as they come. Also, he does everything possible for you to > settle your case. He dragged us into 5 separate FSCs and each time he would > ask us to sit in a conference room with Defense counsel and try to settle > the case. He also required both our client and a defense insurance adjuster > to personally appear at each Final Status Conference. > > FACTS > 81-year-old Plaintiff was walking down the outside stairs at his > second-story apartment when his foot caught on "something" on the second > step causing him to fall down the stairs and hit his head at the bottom. He > wasn't holding onto the handrail because he had his keys in one hand and > his phone in the other. He was not paying attention to the next step. > Nobody saw him fall. Nobody knows what he actually tripped on. His wife > drove him to the ER where they found a small bump on his forehead but no > bleed on the CT scan and sent him home. > > About three weeks later, Plaintiff told his landlord/defendant about the > fall and said he couldn't work full time so he needed $1,500 to cover rent > at his auto body shop. The landlord/defendant went and had an attorney > draft a release, showed up a week later with a $1,500 check, and told > Plaintiff he'd get the money if he signed. Plaintiff didn't read it, didn't > have a lawyer look at it, signed his name, and cashed the check. That > release obviously turned out to be a huge problem. (We beat a MSJ on it so > if you ever run into this issue, I would be happy to share it.) > > Three weeks after that, Plaintiff 's headaches got much worse and he drove > himself back to the ER. This time the imaging showed a moderate acute > subdural hematoma and the next day he underwent a right frontal craniotomy > to relieve the pressure. Surgery went well. Since then he's just kept up > with his neurosurgeon, neurologist, and PCP. > Plaintiff's TBI symptoms post incident essentially mirrored someone that > was suffering from dementia and early onset Alzheimer's. So much so that > his treating neurologist prescribed him medication for early onset dementia > to help his memory issues. Plaintiff's complaints at the time of trial were > headaches once per month and random instances of forgetfulness. > > LIABILITY > The stairs Plaintiff fell on hadn't been touched since they were built in > 1996. A month after the fall, the landlord tore them down and rebuilt them. > That left us with nothing but a few photos Plaintiff took a few days after > the fall to work with as evidence because Judge Hofer ruled the rebuilt > stairs were a subsequent remedial measure and would not budge. He would not > even entertain oral arguments or trial briefing on the exceptions. > > The bigger liability fight was over the release. I have attached the > release to this post and encourage you to take a look at it and tell me > what your thoughts are because 9/12 jurors thought it meant nothing but > 3/12 said it was clear and convincing enough to meet the requirements of a > waiver. The Defense told the jury they should award $0 because Plaintiff > had signed this release. > > Both sides had real exposure here. The adjuster seemed to think the > release was very clear. It had a title, a date of loss, a short description > of the incident, and a 1542 clause, etc. There was definitely enough to > lose sleep over. Of course, Gary Dordick was not too concerned with it and > saw it as what he calls "Blood in the Water". We used it to tell the full > story to the jury. > > Judge Hofer gave CACI 336 slightly modified on the release issue. We > argued for CACI 320 "Interpretation - Construction Against Drafter" but > Hofer said no. Question 1 on the verdict form asked the jury whether > Plaintiff had waived his right to sue the Defendant. Jurors told us > afterward that it was obvious nobody actually understood what they'd > signed, so they couldn't call it clear and convincing evidence of a waiver. > > DAMAGES > Plaintiff is now 83 and a lot of his symptoms look almost identical to > what you'd see in an average 83-year-old in the early stages of dementia or > Alzheimer's. Proving that his cognitive decline traced back to the fall and > not just ordinary aging was very difficult especially considering the fact > that our client is an old school auto mechanic that didn't complain about > anything. This is where Dr. Daniel Franc's testimony came in which was very > good. He was able to explain the brain injury to the jury and basically say > that in reality, "the lights might be on but nobody is home". Dr. Franc's > presentation with the jury and his model brain was very effective. > > Another issue we had was our jury struggled to understand why a man who > had been living independently for three years since his brain surgery > suddenly needed millions of dollars in future care. Two jurors told me > afterward, almost apologetically, "We thought this type of care was for > rich people and not something everyone could afford." > > The defense went after our experts the way you'd expect. They hit Dr. > Franc, our neurologist, for having only physically examined Plaintiff once > in person, with every other evaluation done over Zoom. They went after Mark > Burns on the theory that his opinions were unreliable because he never > personally measured the stairs Plaintiff tripped on. Of course he didn't > because the stairs were torn down almost immediately after the fall, before > anyone had the chance. Burns's measurements came straight from a handyman's > deposition we'd taken a year earlier that did the remodel. We argued to > Judge Hofer that by going down this road, defense had opened the door to > letting us ask Burns on re-direct why he couldn't measure the stairs. Hofer > shut it down right away. Tough ruling to take in the moment but Gary > Dordick reminded us afterward you end up thanking the judge for every bad > ruling he gives once you get a good verdict because it makes the verdict > that much harder to take away from you on appeal. > > PRE-TRIAL > The landlord/defendant carried a $1M underlying policy and a $2M umbrella, > both through Farmers. After mediation we came down to $950k and they came > up to $525k. A few weeks before trial, we sent a last-chance 998 for $900k. > No response. Right before voir dire, they moved to $625k. > > THE VERDICT > As Dylan mentioned above, the first question we got from the jury was a > request for a calculator. What he didn't mention was that after the jury's > second question (requesting a readback of Dr. Franc's future care > recommendations) defense counsel looked over at me and simply said, "Merry > Christmas." > > About an hour after that, three buzzes…we had a verdict. > • $719,495.00 - Future Economic Damages > • $225,000.00 - Past Non-Economic Damages > • $525,000.00 - Future Non-Economic Damages > • $80,778.87 - Stipulated Past Medical Specials > • $1,550,273.87 - Total > > Dylan Dordick and I are incredibly fortunate to be able to call our dads > before, during, and after trial to share the good, the bad, and the ugly. I > want to give a special thank you to our dads, Jeff Molchan and Gary > Dordick, for their guidance, "wisdom", and support that contributed to the > verdict. > > At the end of the day, our facts were not great and some of the judges > rulings were wrong but our client is a good person that deserved this > verdict and I have no doubt the jury was proud to give him every dollar > they did. > > Cheers, > > Josh Molchan > > > > > > >
AI Analysis:
This message does not help answer the user's question about 'injury.' The message is a brief congratulatory note requesting a copy of an opposition to a Motion for Summary Judgment regarding a release, in the context of a $1.55 million verdict at the Glendale Courthouse. While it references a legal case that may tangentially involve a workplace injury, the message itself contains no substantive information about injury — no discussion of injury type, causation, legal standards, compensability, or any other aspect of injury law. It is simply a social/administrative exchange between attorneys and provides no answer to the user's question.
Congrats!! Can you share the opp to the MSJ regarding the release. Thanks Loren
AI Analysis:
This message does not help answer the user's question about 'injury.' The message is a discussion thread about attorney civility, State Bar discipline, and commentary about a specific defense attorney (Aman Lal) and the demeanor of former plaintiff attorneys who switched to defense work. It references case law about attorney conduct and court discretion to dismiss cases for abusive behavior, but none of this content addresses the topic of injury in any substantive legal sense relevant to workers' compensation. The word 'injury' does not even appear in the message. This is entirely tangential to the user's inquiry.
"Carolin Shining" Date: August 07, 2026 1:55:00 PM Subject: Re: Progressive staff counsel attorney Aman Lal Reply to list Reply to sender Print Even though there is mixed case law on the 1 st Amendment and civility, I think the State Bar can still order people to sit in a corner and watch civility webinars… -Carolin ( See Adams v. Koenig , No. 21-CV-08545-JST, 2025 WL 2494367, at *5 (N.D. Cal. Aug. 29, 2025) (“It is within a trial court's discretion to dismiss a plaintiff's case with prejudice because of the plaintiff's abusive behavior towards opposing counsel and the Court); In re Comfort , 284 Kan. 183, 207, 159 P.3d 1011, 1028 (2007)(Supreme Court of Kansas approves public censure); cf U.S. v. Wunsch , 84 F.3d 1110 (9 th Cir., 1996)). Carolin Shining Shining Law 475 Washington Boulevard Marina del Rey, CA 90292 carolin@shininglawfirm.com Direct: 310-490-4383 From: Kenneth Shy (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, May 20, 2026 3:56 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Progressive staff counsel attorney Aman Lal List: caala-workproduct Sent by: Kenneth Shy (Reply Privately) Search Ara, That explains it. The angriest defense lawyers I've ever been against are the failed plaintiff lawyers like Robert Miller and Jon Birdt (I liked the guy but man was he aggressive when he went defense). -- Sincerely, Kenneth R. Shy, Esq. 6700 Fallbrook Ave, Suite 207 • West Hills, CA 91307 Phone: (818) 334-5711 | Fax: (818) 394-6448 | www.mrparkerlaw.com The information contained in or attached to this e-mail is intended only for the use of the named addressee. If you are not an intended recipient of this e-mail, you must not copy, distribute or take any further action in reliance on it and you should delete it and notify the sender immediately. In addition, this e-mail may contain confidential, proprietary or legally privileged information, and a mistransmission of this e-mail is not intended to waive, nor shall it constitute a waiver, of any privilege or confidentiality or proprietary rights NOTICE REGARDING E-SERVICE : All pleadings and time sensitive correspondence must be sent to service@mrparkerlaw.com . M.R. Parker Law P.C. accepts electronic service only at this e-mail address. On Wed, May 20, 2026 at 3:53 PM Ara Saroian (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Ara Saroian (Reply Privately) Search He was a solo plaintiff's attorney for a year before turning to defense. Probably explains why he's jaded against us On Wed, May 20, 2026 at 3:52 PM Kenneth Shy (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Kenneth Shy (Reply Privately) Search Thank you for the information Max. You think he'd have learned by now to not put such statements in writing. I've never seen this kind of behavior in a case that I can remember. -- Sincerely, Kenneth R. Shy, Esq. 6700 Fallbrook Ave, Suite 207 • West Hills, CA 91307 Phone: (818) 334-5711 | Fax: (818) 394-6448 | www.mrparkerlaw.com The information contained in or attached to this e-mail is intended only for the use of the named addressee. If you are not an intended recipient of this e-mail, you must not copy, distribute or take any further action in reliance on it and you should delete it and notify the sender immediately. In addition, this e-mail may contain confidential, proprietary or legally privileged information, and a mistransmission of this e-mail is not intended to waive, nor shall it constitute a waiver, of any privilege or confidentiality or proprietary rights NOTICE REGARDING E-SERVICE : All pleadings and time sensitive correspondence must be sent to service@mrparkerlaw.com . M.R. Parker Law P.C. accepts electronic service only at this e-mail address. On Wed, May 20, 2026 at 3:43 PM Maximilian Lee (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Maximilian Lee (Reply Privately) Search Dear Kenneth: Aman definitely has keyboard rage issues. When he was defending a premises liability case, he emailed me: "I think you and your firm are terrible lawyers. I look forward to this trial." He later apologized when I called out his behavior in my successful opposition to MSJ. We went to a useless MSC, he then left the firm, and the case was resolved. Very Truly Yours, Max Lee Law Office of Maximilian Lee, APC 2916 W. 164th St., Second Floor Torrance, CA 90504 Direct: 1.626.808.4157 Office/Fax: 1.213.769.6529 Please take notice that this email is intended solely for the named recipient or the recipient's agent, and may contain legally privileged information. If you are not the named or intended recipient, please do not copy, disclose or disseminate this email or its contents, and please contact the sender as soon as possible. Thank you for your cooperation. On Wed, May 20, 2026 at 3:32 PM Isaac Toveg (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Isaac Toveg (Reply Privately) Search Its tough for a defamation as there are litigation privileges Isaac Toveg. On Wednesday, May 20, 2026 at 03:21:47 PM PDT, Kenneth Shy (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Kenneth Shy (Reply Privately) Search We have a disputed liability case with a police report and he accused me twice today of hiring my client's favorable witness, notwithstanding the fact the witness was in the police report way before my firm ever signed the case up. I think he may be having a breakdown of some sort but do I have any remedy for such a defamatory statement in the context of litigation? Anyone know who his supervisor is? -- Sincerely, Kenneth R. Shy, Esq. 6700 Fallbrook Ave, Suite 207 • West Hills, CA 91307 Phone: (818) 334-5711 | Fax: (818) 394-6448 | www.mrparkerlaw.com The information contained in or attached to this e-mail is intended only for the use of the named addressee. If you are not an intended recipient of this e-mail, you must not copy, distribute or take any further action in reliance on it and you should delete it and notify the sender immediately. In addition, this e-mail may contain confidential, proprietary or legally privileged information, and a mistransmission of this e-mail is not intended to waive, nor shall it constitute a waiver, of any privilege or confidentiality or proprietary rights NOTICE REGARDING E-SERVICE : All pleadings and time sensitive correspondence must be sent to service@mrparkerlaw.com . M.R. Parker Law P.C. accepts electronic service only at this e-mail address. -- Regards, Ara Saroian Attorney at Law SAROIAN LAW, PC. Mailing Address ONLY: 5632 Van Nuys Blvd., Suite 1309 Sherman Oaks, CA 91401 Telephone: (818) 261-7696 Facsimile: (818) 698-6566 ara@saroianlaw.com www.saroianlaw.com ABOUT THIS EMAIL: The information transmitted in this electronic message is intended only for the person(a) and/or entity(ies) to which it was addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this electronic message in error, please IMMEDIATELY contact the sender and IMMEDIATELY delete any and all electronic messages, including attachments to said messages, from any computer(s) in receipt of this message. NOTICE REGARDING ELECTRONIC SERVICE ON SAROIAN LAW, PC.: Saroian Law, PC accepts service of all documents, pleadings or notices by electronic means pursuant to C.C.P. § 1010.6(e)(2).
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is a brief reply to a thread about a neuroradiologist referral, simply naming 'Brian King MD' as a recommendation, followed by the sender's email signature and confidentiality disclaimer. It contains no substantive discussion of injury, workers' compensation injury claims, injury analysis, or any related legal or medical topic that would help answer a question about injury. The message does not address the topic of injury in any meaningful way.
Brian King MD. PEJMAN BEN-COHEN TRIAL LAWYER/PARTNER Carpenter & Zuckerman 8827 W. Olympic Boulevard, Beverly Hills, CA 90211 T 310-273-1230 ext 153 F 310-858-1063 czrlaw.com This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom the email is addressed. If you are not the named addressee, you are prohibited from disclosing, copying, or disseminating this email in any manner. Instead, please delete this email from your system and notify the sender of the error. The sender may be contacted by return email or by calling (310) 273-1230.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is a solicitation for trial counsel for a Bay Area civil case involving defamation, assault, battery, and negligence claims — it does not provide any substantive legal information, analysis, or guidance about injury-related workers' compensation law or any other legal doctrine. While the word 'injury' appears incidentally in the message (describing alleged injuries from a false police report), the message does not answer or address any legal question about injury. It is simply a referral request/advertisement for litigation counsel in a personal injury/civil rights case that is entirely unrelated to workers' compensation. A reader would learn nothing substantive about the topic of 'injury' in any legal analytical sense from this message.
Colleagues, Seeking seasoned trial counsel for a Bay Area case with a jury trial set for April 2027. The original personal injury complaint has resolved, so our client's cross-claims are now the only claims standing and she goes to trial as the sole plaintiff. Liability. The accuser falsely reported to police that our client struck her with a vehicle, knocking her out of her shoes, caused all kinds of injuries. Dashcam from that vehicle recorded the entire encounter and eyewitnesses all contradicted the false accusation. Police failed to do even basic investigation before forcefully arresting our client on multiple felony and misdemeanor charges. The arrest alone cost her a $300K/year job. The accuser eventually conceded she was not struck and did not fall out of her shoes. The DA ended up dismissing all charges related to the accuser after reviewing the accuser's medical records where acccuser's own doctor repeatedly said no causation, even if her story had been true (version 2 was she ended up on the hood of our client's vehicle and jumped off). On the record, DA basically called the accuser a liar and disclosed that the accuser told DA that she hoped our client would lose her professional license and never work again. The now-former DA is on our witness list. Years later in her deposition, the accuser returned to the original account. Our Claims and exposure. Defamation, assault, battery (accuser admitted grabbing our client), negligence, against a $1M personal liability policy. Accuser has substantial personal assets. Open to dismissing intentional torts to preserve coverage, likely retaining one for punitive exposure. Economic damages exceed $1M, plus substantial reputational and professional licensure harm. Posture: Cost-sharing and funding arrangements are open to discussion. Happy to walk through all of it on a call — no surprises. Reply off-list. Thank you. Very truly yours, Un Hui "Oonee" Nam Medical and Law Offices of Dr. Un Hui Nam, M.D, J.D. 1771 Woodside Road Redwood City, CA 94061 650.308.9478 Courage is not having the strength to go on; it is going on when you don’t have the strength. I know what it is to be in need and I know what it is to have plenty. I have learned the secret of being content in any and every situation, whether well-fed or hungry, whether living in plenty or in want. Philippians 4:12 NIV But he said to me, "My grace is sufficient for you, for my power is made perfect in weakness.” Therefore I will boast all the more gladly about my weaknesses, so that Christ’s power may rest on me. That is why, for Christ’s sake, I delight in weaknesses, in insults, in hardships, in persecutions, in difficulties. For when I am weak, then I am strong." 2 Corinthians 12:9-10 This electronic communication and its contents may contain confidential and/or legally privileged information. It is intended solely for the recipient(s) identified above. If you are not an intended recipient, you may not review, copy, retain, use, or distribute this message. Unauthorized interception, review, use or disclosure of the contents of this communication is strictly prohibited and may violate applicable laws. If you are not the intended recipient, please contact me immediately, delete the original message from your device(s) and any servers, and destroy all copies of the communication. Please consider the environment before printing this e-mail. In plain non-legalese English: This email contains legal stuff. If it is not for you, please don't read it. You could get into a lot of trouble, and even more trouble if you tell anyone else about it. So, if it's not for you, please delete it and forget you ever saw it. Also, it is not nice to read other people's emails. Thank you!
AI Analysis:
This message does not help answer the user's question about 'injury.' The message is essentially an email signature/disclaimer block from Jim Dicks, a Certified Criminal Law Specialist, with no substantive content whatsoever. It contains only contact information and a standard legal confidentiality disclaimer. There is no discussion of any injury, workers' compensation issues, legal analysis, or any other substantive information that would help answer the user's question about injury.
James Dicks Certified Criminal Law Specialist | California Board of Legal Specialization, jD Law ( 760) 630-2000 (760)630-2002 jdlaw.law jim@jdlaw.law 400 S. Melrose Dr Suite 109, Vista, CA 92081 PLEASE ALLOW 24-48 BUSINESS HOURS FOR A RESPONSE This e-mail message is only intended for the person(s) to whom it is addressed. It may contain confidential and proprietary information and is protected from disclosure. If you are not the intended recipient or a person responsible for delivering it to the intended recipient, you are hereby notified that any review, retention, copying or distribution of this communication is prohibited by law. Please reply to the sender that you have received the message in error, and then delete it. In addition, please be aware that any message addressed to our company is subject to archiving and review by persons other than the intended recipient. Although reasonable precautions have been taken to ensure that no viruses or other harm are present, jD LAW make no warranty or guaranty with respect to, and are not responsible for any loss or damage arising from the receipt or use of this e-mail or attachments. Thank you.
AI Analysis:
This message does not help answer the user's question about 'injury.' The message is a brief follow-up note indicating that a Miami attorney was found to handle a Carnival cruise slip and fall matter. It contains no substantive legal information about injury law, workers' compensation, or any other topic that would help answer the real question. It is merely an administrative update closing out a referral request, with no analytical or informational value relevant to the user's inquiry.
Thank you. We already found a Miami attorney to handle the matter.
AI Analysis:
This message does not help answer the user's question about 'injury.' The message is essentially a signature block from attorney Paulina Belovarski responding to a request for an attorney to handle a Carnival cruise slip and fall case. It contains no substantive legal information, analysis, or discussion about injury — whether related to workers' compensation, legal standards, definitions, case law, or any other substantive content. The message consists entirely of contact information, a CCP § 1010.6 electronic service notice, a confidentiality disclaimer, and a copyright notice. There is no content that would help a reader learn anything meaningful about the topic of injury.
Sincerely, Paulina Belovarski, Esq. Belovarski Law phone 424.234.9777 fax 805.380.8803 30700 Russell Ranch Rd #250 Westlake Village CA 91362 paulina@belovarskilaw.com Instagram Website Consultation Please be advised, pursuant to CCP § 1010.6(b)(4), I hereby request electronic service of all documents in this matter. Please serve all future documents on me electronically at records@belovarskilaw.com . CONFIDENTIALITY NOTICE : This email and any attachments are confidential and may contain information protected by the attorney-client privilege or work product doctrine. They are intended solely for the named recipient(s). If you are not the intended recipient, please notify the sender immediately and delete all copies without reading, copying, or forwarding them. DISCLAIMER : This communication may or may not constitute legal advice depending on the nature of the sender's relationship with the recipient. No attorney-client relationship is created by this email alone. Any such relationship requires a signed written engagement agreement. © 2026 Belovarski Law. All Rights Reserved.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is a brief congratulatory reply from Ron Janfaza about a $1.55 million verdict, expressing surprise about getting around a Release. It contains no substantive information about injury — no discussion of the nature of an injury, legal standards, medical evidence, causation, or any other content that would help answer a question about injury. The message is purely a social/congratulatory response with no legal substance relevant to the topic of injury.
Wow this is great! I was unaware that you could get around a Release that way. Sounds like amazing results for this type of case. Appreciate the details of the case. Mazal tov! Talk soon!
AI Analysis:
The user's real question is a keyword search for 'injury.' This message does not address injury in any substantive way. It is a thread about a Motion in Limine (MIL) regarding whether dollar amounts can be mentioned during voir dire in a civil trial, with attorneys sharing work product documents. The word 'injury' does not even appear in the message, and the content — procedural discussion about voir dire and MIL opposition — does not help answer any question about injury in a workers' compensation or legal context. This message is entirely irrelevant to the real question.
"Greyson Goody" Date: August 06, 2026 2:34:00 PM Subject: Re: Motion in Opposition to Defendants MIL to Preclude mention of Dollar Amounts in Voir Dire Reply to list Reply to sender Print Attachments: 1. voir dire numbers.docx (145 K) List: caala-workproduct Sent by: Greyson Goody (Reply Privately) Search Try this, it should work. -----Original Message----- From: rsflaw2000@yahoo.com Sent: August 03, 2026 11:46:00 AM To: caala-workproduct@lists.trialsmith.com Subject: Re: Motion in Opposition to Defendants MIL to Preclude mention of Dollar Amounts in Voir Dire Eric, The Motion was not attached. Bob On Friday, July 31, 2026 at 12:24:33 PM PDT, Eric Traut (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: ' ' List: caala-workproduct Sent by: Eric Traut (Reply Privately) ' Search ' ' Sending you one I just won last month From: Bob Fink (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, July 31, 2026 12:22 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Motion in Opposition to Defendants MIL to Preclude mention of Dollar Amounts in Voir Dire ' ' List: caala-workproduct Sent by: Bob Fink (Reply Privately) ' Search ' ' Anyone have an opposition to defendants MIL. Thank you Sending you one I just won last month From: Bob Fink (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, July 31, 2026 12:22 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Motion in Opposition to Defendants MIL to Preclude mention of Dollar Amounts in Voir Dire ' ' List: caala-workproduct Sent by: Bob Fink (Reply Privately) ' Search ' ' Anyone have an opposition to defendants MIL. Thank you
AI Analysis:
The user's real question is a keyword search for 'injury,' which in this legal listserv context would be seeking substantive information about workers' compensation injury law, case strategies, or related legal principles. This message is a referral request for a maritime/admiralty personal injury attorney to handle a Carnival cruise ship slip-and-fall case. While it involves a physical injury, it does not address workers' compensation law, California workers' comp injury standards, or any substantive legal question about 'injury' in the workers' comp context. It is simply a case referral posting for a completely different area of law (maritime tort), and a reader would learn nothing about the answer to any substantive legal question regarding injury from this message.
Have a matter where client was walking on Lido deck on Carnival cruise line ship when walked past condiment station and slipped and fell due to red liquid on deck that appeared to be catsup. An incident report was filed. The liquid had previously been reported to the crew, but had no signs were posted and it had not been cleaned up. He was seen at medical on board, and at local hospital after ship docked. Continued treatment with PCP and neurologist.
AI Analysis:
This message does not help answer the user's question about 'injury.' The message contains only a signature block from Howard S. Blumenthal, Esq., with contact information (phone, fax, cell numbers). There is no substantive content whatsoever — no discussion of injury, no legal analysis, no case information, no procedural guidance. The subject line references 'Aspire Not Producing Affidavit of No Other Insurance/Course and Scope,' which is tangentially related to workers' compensation but does not address injury in any meaningful way. A reader would learn nothing about injury from this message.
Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059
AI Analysis:
The user's real question is a keyword search for 'injury.' This message discusses methods for effectuating service on difficult-to-locate defendants — specifically serving corporate defendants via the Secretary of State versus service by publication. The word 'injury' appears only incidentally in the firm name 'Niral Patel Injury Law' in the email signature, not as substantive content addressing any legal question about injury. The message does not provide any information that would help answer a question about injury in a workers' compensation or legal context. This is purely a procedural discussion about service of process with no substantive relevance to the topic of injury.
"Richard Avetisyan, Esq" Date: August 05, 2026 6:20:00 PM Subject: Re: Best method for effectuating service on a difficult to locate Defendant Reply to list Reply to sender Print List: caala-workproduct Sent by: Richard Avetisyan (Reply Privately) Search With the corporate defendant courts usually want you to serve it via Secretary of State especially if it's a California corporation. Publication is a last resort measure for individual defendants. Sincerely, Richard A. Avetisyan, Esq. ALG Avetisyan Law Group1700 W. Magnolia Blvd., Suite 200Burbank, California 91506 Direct (818) 641-1110 | Fax (818) 641-1140 richard@avetisyanlaw.com On August 5, 2026, at 15:46, Niral Patel (caala-workproduct listserver) < caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search Can you serve both the corp. and individual via publication to save some work in lieu of also seeking leave to serve the Sec of State? Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. -----Original Message----- From: richard2@avetisyanlaw.com Sent: August 05, 2026 5:39:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Best method for effectuating service on a difficult to locate Defendant I dealt with something similar very recently but only with the corporate defendant. After my due diligence including some of the things you did, I ended up getting an order from the court to serve the corporate defendant via Secretary of State. Considering your efforts here I don't think you'll have any problems getting that order. For the individual defendant get an order for publication. List: caala-workproduct Sent by: Brandon Shiener (Reply Privately) Search Hi all, I have named a corporation and the owner of the corporation as Defendants in a premises liability case. The premises was/is not in active operation, so there was no one to serve at that location. After running skip-traces on both Defendants, I attempted service with a process server at multiple addresses in Southern California and Georgia without success. Many of the addresses ended up being UPS/Fed-Ex stores. All of the residences were either empty or the tenants were unfamiliar with the Defendants. I then hired a private investigator, who has also had no success over the last three months. Out of the remaining options for effectuating service, which option would you recommend? Thank you,
AI Analysis:
The user's real question is a keyword search for 'injury.' This message does not substantively address any legal question about injury — it discusses procedural methods for effectuating service on a difficult-to-locate defendant (serving a corporation via Secretary of State and an individual via publication in a premises liability case). The word 'injury' appears only incidentally in the attorney's firm name ('Niral Patel Injury Law') and email signature, not as substantive legal content answering any question about injury. This message provides no information that would help someone learn anything about the topic of injury in a workers' compensation or legal context.
"Niral Patel" Date: August 05, 2026 5:46:00 PM Subject: Re: Best method for effectuating service on a difficult to locate Defendant Reply to list Reply to sender Print List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search Can you serve both the corp. and individual via publication to save some work in lieu of also seeking leave to serve the Sec of State? Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. -----Original Message----- From: richard2@avetisyanlaw.com Sent: August 05, 2026 5:39:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Best method for effectuating service on a difficult to locate Defendant I dealt with something similar very recently but only with the corporate defendant. After my due diligence including some of the things you did, I ended up getting an order from the court to serve the corporate defendant via Secretary of State. Considering your efforts here I don't think you'll have any problems getting that order. For the individual defendant get an order for publication. List: caala-workproduct Sent by: Brandon Shiener (Reply Privately) Search Hi all, I have named a corporation and the owner of the corporation as Defendants in a premises liability case. The premises was/is not in active operation, so there was no one to serve at that location. After running skip-traces on both Defendants, I attempted service with a process server at multiple addresses in Southern California and Georgia without success. Many of the addresses ended up being UPS/Fed-Ex stores. All of the residences were either empty or the tenants were unfamiliar with the Defendants. I then hired a private investigator, who has also had no success over the last three months. Out of the remaining options for effectuating service, which option would you recommend? Thank you,
AI Analysis:
The user's real question is a keyword search for 'injury.' This message is a referral request from an attorney at M&Y Personal Injury Lawyers seeking recommendations for attorneys who handle interpleaders and minors' compromises. While the firm name contains the word 'injury,' the message does not address, explain, or provide any substantive information about injury-related legal topics, workers' compensation injury claims, injury law, or any other topic that would help answer a question about 'injury.' The message is purely an attorney referral solicitation with no substantive legal content relevant to the topic of injury.
"Daniel Reeves" Date: August 04, 2026 5:15:00 PM Subject: Looking for Attorney for Interpleader, Minor's Comps, Etc Reply to list Reply to sender Print List: caala-workproduct Sent by: Daniel Reeves (Reply Privately) Search Mates, My firm is looking for an attorney that can help us file interpleaders and assist with minors' compromises. Does anybody have any recommendations? Or if you are interested, please email me directly daniel@mylawcompany.com. Thank you. Daniel J. Reeves, Esq. M&Y Personal Injury Lawyers 6300 Wilshire Blvd, Suite 807 Los Angeles, CA 90048 Tel: 877.771.8175 ' Direct: 323.505.6780 Fax: 877.877.5057 Email: daniel@mylawcompany.com Web: www.mylawcompany.com Privileged/Confidential information may be contained in this message. If you are not the addressee indicated in this message (or responsible for delivery of the message to such person), you may not copy or deliver this message to anyone. In such case, you should destroy this message and kindly notify the sender by reply email. Please advise immediately if you or your employer does not consent to Internet email for messages of this kind. Opinions, conclusions and other information in this Message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it.
AI Analysis:
This message does not help answer the user's question about 'injury.' The message is essentially a non-substantive acknowledgment ('Thanks and all good suggestions') with no actual legal content, followed by the sender's contact/signature information. While the subject line references injury claims in the context of a third-party auto case, the body of the message contains zero substantive information about injury — no legal analysis, no case law, no procedural guidance, no factual discussion. A reader would learn nothing about injury from this message.
Thanks and all good suggestions. Thank you PLEASE NOTE OUR NEW OFFICE NUMBER BELOW Richard Weiss, Esq. rweiss@richardweisslaw.com LAW OFFICES OF RICHARD WEISS 10350 Santa Monica Boulevard, Suite 295 Los Angeles, CA 90025 310-734-7581 ph. 310-553-0036 ph. 310-553-0067 fax Nevada Office: 10161 Park Run Drive, Suite 150 Las Vegas, Nevada 89145 702-508-9516 ph. 702-508-9517 fax THE CONTENTS OF THIS MESSAGE ARE CONFIDENTIAL WORK
AI Analysis:
The user's real question is a keyword search for 'injury.' This message contains only a signature block from Howard S. Blumenthal, Esq., with contact information (phone, fax numbers) and a subject line referencing a 'Tesla BI Claim Issue.' There is no substantive content whatsoever — no discussion of injury, no legal analysis, no case information, no insights that would help answer any question about injury in the workers' compensation context. The message body is entirely a contact signature with no informational value related to the real question.
Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059
AI Analysis:
This message does not help answer the user's question about 'injury.' The message contains only a signature block from Howard S. Blumenthal, Esq., with contact information (phone, fax numbers) and a subject line referencing a 'Hit and Run' discussion. There is no substantive content about injury, its definition, legal standards, compensability, or any other aspect that would help answer a question about injury in the workers' compensation context. The message provides no informational value whatsoever regarding the real question.
Howard S. Blumenthal, Esq. Law Offices of Howard S. Blumenthal Office: 424-260-1816 Cel: 661-993-1181 Fax: 424-316-3059
AI Analysis:
This message does not help answer the user's question about 'injury.' The message is a one-line reply stating 'The Motion was not attached,' which is purely an administrative/procedural note about a missing attachment in a thread about a Motion in Limine regarding dollar amounts in voir dire. It contains no substantive information about injury, its definition, legal standards, compensability, or any other aspect related to the topic of injury in workers' compensation law.
The Motion was not attached.
AI Analysis:
The user's real question is a keyword search for 'injury.' This message does not substantively address any legal question about injury — it is simply a follow-up request for information about a specific judge (Hon. Wendy G. Getty) in Solano County for a personal injury case. The word 'injury' appears only incidentally in the law firm name 'Niral Patel Injury Law' and as a descriptor of the case type. No substantive information about injury law, injury claims, injury standards, or any related legal question is discussed. A reader would learn nothing about the topic of 'injury' from this message.
Following up on this request for insight! On Thu, Jun 25, 2026 at 4:22 PM Niral Patel (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search Anyone have information on Hon. Wendy G. Getty from in Solano County? I have a fairly large and semi-complex PI case in that department. Niral Patel Injury Law Niral Patel 3333 Michelson Dr. Suite 300 Irvine, CA - 92612 Office #: (949) 289-9911 Direct #: (949) 325-0290 FAX #: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. -- -- ALINA S. VULIC, ESQ., TRIAL LAWYER This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom the email is addressed. If you are not the named addressee, you are prohibited from disclosing, copying, or disseminating this email in any manner. Instead, please delete this email from your system and notify the sender of the error. The sender may be contacted by return email at alina@alinaesquire.com or by calling (424) 333-5368.
AI Analysis:
This message does not answer the user's question about 'injury.' The message contains only a signature block from Brian Chase, Managing Partner at BestAttorney.com, with contact information, a confidentiality disclaimer, and a notice about attorney-client relationships. There is no substantive content whatsoever — no discussion of injury, no legal analysis, no case information, no practical insights. The subject line references an elder neglect/med mal arbitrator inquiry, which is unrelated to the user's question about injury in the workers' compensation context. This message provides zero informational value in response to the user's question.
Sincerely, Brian Chase Managing Partner www.BestAttorney.com Superior Client Representation Since 1978. 1301 Dove Street, STE 120 | Newport Beach, CA 92660 www.BestAttorney.com 800.956.0123 | 949.752.2999 | 949.752.2777 fax PRIVILEGED/CONFIDENTIAL COMMUNICATION: This email and all attachments are intended SOLELY for the recipients as identified in the "To," "CC" and "BCC" lines of this email. If you are not one of the identified intended recipients, your receipt of this email and its attachments is the result of an inadvertent disclosure or unauthorized transmittal. If you are not the one of the identified intended recipients, any dissemination, distribution, storing, sharing, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by telephone and destroy all copies of this message. No waiver of any privilege or work product protection is intended by the accidental distribution or disclosure of this message. NOTICE: NO DUTIES ARE ASSUMED, INTENDED, OR CREATED BY THIS COMMUNICATION. If you have not executed a fee contract, this firm does NOT represent you as your attorney. You are encouraged to retain counsel of your choice if you desire to do so.
AI Analysis:
This message does not answer the user's question about 'injury.' The message contains only a brief apology for typos and grammatical errors (attributed to dictating on a cell phone), followed entirely by standard legal email disclaimers, contact information, and an IRS Circular 230 notice. There is no substantive legal content whatsoever — no discussion of injury, workers' compensation, sidewalk liability, or any other legal topic. A reader would learn nothing about injury from this message.
Please forgive all that typos grammatical errors dictating on my Cell phone. Paul P. Tashnizi Tashnizi Law Firm 28632 Roadside Dr., Suite 220 Agoura Hills, California 91301 Phone: 818-851-9060 Cell: 213-210-6272 email: paul@tashnizila w.com This message and any attachments have been sent by a lawyer and may contain information that is privileged, confidential and exempt from disclosure under applicable law. This email and any associated files transmitted with it are confidential and intended solely for the above named addressees. If you are not the named addressee do not disseminate, distribute, copy or alter this email. Please notify Tashnizi Law Firm at 805-719-2010 or please reply to advise the sender of the error and then immediately delete this message. You will be reimbursed for any reasonable costs. IRS CIRCULAR 230 NOTICE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this communication (or in any attachment) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed in this communication (or in any attachment). P Consider the environment. Please don't print this e-mail unless you really need to.
AI Analysis:
The message is completely empty — it contains no sender, no subject, and no body content. There is nothing to analyze in relation to the user's question about 'injury.' An empty message cannot provide any substantive information to answer the real question.
I always say No to these requests but wonder what are your best arguments/authorities that could shut them down right away.