How to Create a Medical Chronology for Personal Injury Cases (5 Simple Steps)

by Vickie Perry Barker

This article is part of the “How To” blog series in which I offer practical tips that paralegals can use to support attorneys before, during and after litigation. Subscribe to get updates so you won’t miss the next article in the series!

Building a personal injury case is like writing a story. Dates and timing are important when determining what happened to an injured client.

Much like a medical summary, a thorough chronology (or timeline) will help the attorney you support understand the details and variables involved in the injury case.

As a litigation paralegal, you can create a medical chronology that the personal injury attorney will welcome by keeping these 5 simple steps in mind:

  1. Focus on the Dates.
  2. Unorganized medical records can be confusing. You want to create a chronology that includes a clear picture of the injured person’s medical condition and accompanying treatment before, during and after the accident. Every medical timeline should be date driven.

  3. Detail Treatment Information.
  4. It’s important to document the physicians that examined the client as well as the nature and progression of the medical treatment. This will help flesh out specifics about the extent of the client’s injuries and provide easy access to the information you need to locate expert witnesses and schedule depositions in the case.

  5. Highlight the Injury.
  6. In most PI cases, the client’s injuries do not occur in a vacuum, but due to another party’s negligence. The incident that caused the injury should be referenced in the medical chronology. Tying the injury to the medical treatment received is vital to the case.

  7. Itemize Actual (and Special) Damages.
  8. In addition to key medical information, I like to itemize the client’s bills, prescription expenses, lost wages and any other damages incurred as a result of the injury. You should also note how much the client (and the insurance company, if applicable) paid in the course of recovery.  These figures are essential when it comes to proving damages.

  9. Future Medical Treatment?
  10. Some people heal fully from their injuries – which is awesome! However, many others have ongoing heath issues that will plague them for the rest of their lives. It’s important that the medical chronology notes any future treatment the client will need.  This could include surgical interventions, weekly or monthly chiropractic adjustments, special in-home devices or medications.

Once a thorough medical chronology is created, it’s easier to get everyone involved in the case on the same page. It’s also a great tool that can be used strategically to develop a personal injury case that will get the client the best results possible.

How about you? Feel free to share any tips you have for creating medical chronologies and timelines in the comments section below.

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About the Author


Vickie Perry Barker is a Litigation Paralegal. She provides legal and administrative support to attorneys and their in-house teams. You can connect with Vickie on LinkedIn or her semi-personal blog, Atlanta Mompreneur.

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