---
name: "personal_injury_case_files"
description: >
  Build a personal injury case file that is ready to settle or file:
  medical chronologies pinned to source pages, specials tracked against
  bills and records, demand drafts built from the chronology, and a check
  that no figure appears without a source. Use when assembling, auditing,
  or completing a plaintiff injury file, a medical chronology, a specials
  ledger, a lien log, or a settlement demand package.
---

# Personal Injury Case Files

## Purpose

Turn a pile of medical records, bills, photos, and letters into one file a
settlement adjuster, a mediator, or a court can follow without hunting.
The test for every page is simple: can a stranger find the source for this
fact or this figure in under a minute. If not, the file is not ready, no
matter how complete it feels.

Special damages, often shortened to specials, are the losses that come
with a bill, a receipt, or a wage record: medical charges, lost wages,
rental and repair costs, pharmacy charges. General damages are the non
economic harm: pain, loss of function, loss of enjoyment. Under Federal
Rule of Civil Procedure 9(g), an item of special damage claimed in federal
court must be specifically stated. That rule states the working standard
for the whole file: every special, stated, sourced, and totalled.

## Workflow

### 1. Open the file with deadlines and an inventory
- Record the incident date, the parties, the insurers and claim numbers,
  and the theory of the case in one opening memo. Keep facts, witness
  claims, and your own notes in separate paragraphs.
- Find the limitations deadline and any claim notice deadline from the
  controlling statute for the jurisdiction and claim type, and calendar
  both with a wide safety margin. Deadlines vary by state, by claim type,
  and by defendant, and government defendants often carry shorter notice
  rules. Never work from a remembered period.
- Start the records inventory on day one: provider, date range requested,
  date requested, date received, page count, and gaps. Every later step
  reads from this inventory.

### 2. Collect records with valid authorizations
- Use a signed authorization that meets 45 CFR 164.508 for each provider
  release to the firm or representative. Check the six core elements: a
  specific description of the records, who may disclose them, who receives
  them, the purpose, an expiration date or event, and the client signature
  and date. Check the required statements too: the right to revoke in
  writing, whether treatment or payment can be conditioned on signing, and
  the warning that a recipient may redisclose the information.
- Describe records in a specific and meaningful way, such as provider,
  record type, and date range. A bare phrase like all health information
  invites a rejection as too vague.
- Keep the client own right of access separate from a third party
  authorization. The rules, timing, and fees differ, and mixing the two
  routes stalls requests.
- Log bills separately from records. A treatment note proves care happened.
  A bill proves a charge. The specials ledger needs both.
- Preserve liability evidence in parallel: incident or police report,
  photos, scene records, witness names and statements, and property
  damage documents. Pin each item by document name in the file index.

### 3. Build the medical chronology, pinned to the page
- Work in strict date order, one row per event, using
  `assets/chronology-template.csv`. Columns: date, provider, event type,
  plain language summary, diagnosis or finding as recorded, treatment or
  plan as recorded, source document, source page.
- Write facts only. Record what the chart says, in plain words a non
  clinician can follow. Leave legal conclusions, fault language, and
  advocacy out of the chronology. The demand letter is where argument
  belongs.
- Deduplicate. The same visit often arrives twice, once from the provider
  and once from a portal or a prior firm. One event, one row.
- Flag three things in a gap log as you build: missing records for a
  provider or date range the other records mention, contradictions
  between records, and treatment gaps. For each gap, write either the
  explanation a record supports or the follow up you sent. An unexplained
  gap is the first thing an adjuster or defense lawyer will press on.
- Include relevant care from before the incident where the records show
  it, marked clearly as prior care. A prior injury or condition found by
  your own review is a fact to plan around. The same fact first raised by
  the other side at deposition is a problem.
- Have a second person check a sample of entries against the source pages
  before the chronology is used. One wrong date can damage the credit of
  the whole timeline.

### 4. Build the specials ledger against bills and records
- Use `assets/specials-ledger-template.csv`. One row per charge or loss,
  with an item ID, date of service, provider, category, description, the
  amount claimed, and two pins: the bill, receipt, or wage document and
  page, and the record document and page that shows the care or loss was
  tied to the incident.
- Keep billed, adjustments, paid, and balance owed as separate fields, and
  reconcile each row where all four exist: billed minus adjustments minus
  paid equals balance owed.
- Sort wage loss the same way: employer letter or pay records as the money
  source, and a record or work restriction note as the tie to the injury.
  Hours, rate, and days missed must each trace to a document.
- Claim only related items, and write the relation note on the row: which
  referral, order, or visit connects this charge to the incident. Related
  is a judgment counsel reviews, so make the basis visible.
- Total by category and in full with the checker in step 6. The printed
  total is the only specials total anyone quotes from the file.

### 5. Run the lien and subrogation log before valuing anything
- Open the log in `references/liens-and-holdbacks.md` as soon as any
  third party payment shows up in the bills. Check for Medicare
  conditional payments, Medicaid recovery, health plan subrogation,
  hospital or provider liens, workers compensation liens, and auto
  medical payments claims.
- For a Medicare beneficiary, note that CMS treats Medicare as secondary
  under 42 U.S.C. 1395y(b) and recovers conditional payments through the
  Benefits Coordination and Recovery Center when a case settles or is
  paid. Request the conditional payment information early, dispute
  unrelated charges, and plan to confirm the final amount before money
  is disbursed.
- Read the actual plan, statute, or notice behind each claim and pin the
  clause or letter by page. Amount claimed and amount verified are
  separate columns until they match in writing.
- Hold back any disputed amount at settlement, under the arrangement
  counsel directs, and record the release condition in the log.

### 6. Run the source pinning check
- Run the bundled checker on the chronology, the ledger, and any demand
  draft: `python3 scripts/check_case_file.py chronology.csv specials.csv --demand demand.md`
- Fix every error before moving on. An error means an unpinned entry, a
  broken total, an out of order date, or a demand figure that matches no
  ledger line, subtotal, or total and is not labelled as the ask.
- Read the warnings too. Treatment gaps over the threshold you set, and
  likely duplicate entries, need a written explanation in the file or a
  follow up request on record.

### 7. Draft the demand from the chronology and the ledger
- Follow the section order in `references/demand-package.md`: facts,
  liability evidence, injuries and treatment from the chronology, special
  damages from the ledger totals, general damages described in concrete
  terms tied to dated entries, future items only where a provider
  statement or expert report supports them, then one labelled demand
  figure, a response date set with counsel, and an exhibit index.
- Build the narrative from chronology rows, in order. If a sentence in
  the draft is not backed by a row or an indexed exhibit, cut it or go
  get the record that backs it.
- Present general damages as described harm, not as a calculation. No
  statute or rule sets a multiplier or a per day rate for pain and
  suffering. If counsel chooses such a framing as a negotiation argument,
  the draft must present it as an argument, never as a formula the law
  requires.
- Re-run the checker against the final draft. Every dollar figure in the
  letter must now pass: ledger line, category subtotal, grand total, or
  the labelled demand figure, with nothing else left over.

### 8. Apply the settle or file readiness gate
- Treatment status is clear: either care has ended, or the records and a
  provider opinion state the current condition and any future care in
  terms a demand can cite.
- Liability evidence is in the file and indexed, and known weak points,
  such as a fault dispute or a prior condition, are named in an internal
  memo with the plan for each.
- Specials are closed or any open item is listed with the document still
  missing and the date it was last chased.
- The lien log is current, conditional payment figures are requested, and
  no payee is a surprise at disbursement.
- The limitations deadline is checked again and leaves room to file if
  the demand fails. If any gate item fails, finish that item first. A
  demand sent from an unready file sets a low anchor that is hard to
  undo.

## Output Contract

A finished engagement produces:

- `file-opening-memo.md`: parties, claim numbers, theory, deadlines with
  the statute each deadline came from, and the safety margin used
- `records-inventory.csv`: every provider and evidence item, requested
  and received dates, page counts, and outstanding gaps
- `chronology.csv`: the pinned medical chronology, facts only, in date
  order, checked by a second reviewer
- `gap-log.md`: missing records, contradictions, and treatment gaps, each
  with an explanation or a dated follow up
- `specials.csv`: the pinned specials ledger with category totals and a
  grand total produced by the checker
- `lien-log.md`: every lien, subrogation, or conditional payment claim,
  with its source document, amount claimed, amount verified, and status
- `demand.md` plus an exhibit index: the demand package, with every figure
  passing the checker, ready for counsel review and client approval

The worked example in `assets/worked-example/` shows all three core files
for one fictional case: the chronology, the ledger totalling $9,178.40 in
documented specials, and a demand draft whose figures all trace back to
the ledger.

## Operating Rules

1. This skill is case organization and drafting support, not legal advice.
   A licensed attorney in the controlling jurisdiction reviews the file,
   sets the demand figure, and makes every call on fault, damages law,
   liens, and deadlines before anything is sent or filed.
2. No figure without a source, no fact without a pin. If a number or a
   date cannot be traced to a document and page in the file, it stays out
   of the chronology, the ledger, and the demand.
3. Never invent or round a medical fact, a charge, a wage figure, or a
   deadline. Copy figures from the source document, and let the checker
   do the adding.
4. Jurisdiction controls. Limitations periods, notice rules, fault rules,
   collateral source treatment, damages caps, and lien rules all vary.
   Verify each one from the controlling statute, rule, plan, or case law
   for this case. State the source you used in the file memo.
5. Keep the chronology neutral. Argument, characterizations of fault, and
   settlement positions live in the demand and in internal memos, never
   in the timeline that experts and adjusters will treat as the record.
6. Guard the records. Medical files hold highly sensitive information.
   Store them with access limited to the case team, send only what the
   demand or a valid request calls for, and log every copy sent out,
   with the date, recipient, and exhibit list.
7. Do not disburse against an open lien log. Unverified or disputed
   amounts stay held back until they are resolved in writing.
8. Update the file as records arrive. A chronology or ledger that stops
   at the first batch of records is stale the day the next batch lands.
   Re-run the checker after every update.