Section 3 Establishing Nature and Extent of Pain and Suffering

LibraryDamages 2012

The following questions, when explored with the client, should quickly give counsel a good idea of the nature and extent of a client’s pain and suffering:

1. Describe what conditions, activities, or treatment makes your injuries more painful.

2. Do you expect your pain to continue into the future? If so, how long and what is the basis for this expectation?

3. What have your treating physicians told you about this subject?

4. What practical difficulties do you experience with the pain you suffer?

5. Has your...

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