Section 4 Documenting Proof of Pain and Suffering

• Library: Damages 2012

If the client’s physical or mental condition is expected to change, counsel can preserve the factual basis necessary to effectively prove these changes at trial. Photographs of any injured body part should be considered and taken, if applicable. Arrangements should be made to periodically photograph the client to document the progression of any changes. A videotape of the client demonstrating the nature of the injury and the limitations it creates might be useful. If the client’s condition is chronic or...