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Do the Due, Diligence: Trial Prep

trial

We recently encountered a challenging situation; In one matter: 20 witnesses to verify and serve, a week before the trial date. There were a myriad of reasons why the attorney was unprepared for trial (several incidents came to light during this hectic process) but below, we pass along several generic trial prep techniques:

1. Consult with your trial prep person well before trial.

Meeting with your trial prep firm allows the investigator to become aware of the case facts, and allots him/her the time to review the matter and then, formulate and execute an operations plan.  (There will always be last minute filings, service, subject locates… that have to be performed.  An experienced trial prep firm, however , has resources already in place for those unforeseen events.)

2. Basic Paperwork and Activity To Have Completed Pre-Trial

– Special Power of Attorney.  This should be obtained from the injured client from the outset.  (In this recent case, the client lived several states away and was not readily able to come up and sign authorizations.)

– HIPAA authorizations.  If there is a hint that the records may contain medical information,  a duly executed HIPAA authorization form must be attached to the subpoena request for testimony and or records.

– So Ordered Subpoenas.  Generally, among other criteria, if a city, state or federal agency is involved, a So Ordered Subpoena (signed by a judge) must be obtained at the trial court.

– Subject Locates – Don’t use the DIY  online searches that are readily available online.  The vast majority  of these sites yield information that, if correct, ages out at about 12 to 18 months old already.   Have your investigator conduct comprehensive locates, especially in cases that, for whatever reason (e.g., attorney substitution) have gone on for a while,

Tip:  When dealing with EMS documents, note the shield numbers.  If the shield number is 6,000 or above (e.g. Shield# 7206 or 6024) this is a private ambulance that has responded.  Do not subpoena the FDNY at MetroTech for the Ambulance Call Report.  They won’t have it.  In the section underneath “Comments” on the ACR, there is a field for Hosp #.  The number in that field reveals the hospital associated with the responding ambulance.   (There may be one of two numbers written into this field; a 3 digit number is the trauma center designation and the number in parens is the FDNY hospital code assignment.  Almost all EMS personnel use the 2 digit FDNY code. n parentheses)  See below for NY County Hospital Codes. (For other boroughs: shoot us an email, we’ll send you the links.)

Hospital Information

Hospital Name Disposition Code Hospital Name Disposition Code
Bellevue Hospital 712 (02) Beth Israel Medical Petrie Campus 713 (03)
Cabrini Medical 715 (63) Goldwater Memorial Hospital – Coler Site 714
Goldwater Memorial Hospital – Goldwater Site 720 Harlem Hospital 721 (07)
Hospital Joint Diseases Ortho. Inst. 735 Hospital For Special Surgery 723
North General Hospital 758 (09) Lenox Hill Hospital 728 (11)
Manhattan Eye, Ear & Throat Hospital 730 (05) Memorial Hospital – Cancer & Allied Diseases 731 (08)
Metropolitan Hospital 732 (12) Mount Sinai Hospital 734 (13)
New York Eye & Ear Infirmary 736 New York Presbyterian Hospital Weill Cornell 737 (14)
New York University Downtown Hospital 941 (01) New York University Hospitals 739 (15)
New York Presbyterian Hospital
Columbia Presbyterian Division
742 (17) New York Presbyterian Hospital – Allen Pavillion 749 (16)
Rockefeller University Hospital 743 St. Clares Hospital & Health 746 (19)
St. Lukes-Roosevelt Hosp.
Roosevelt Hospital Division
759 (18) St. Lukes-Roosevelt Hosp.
St. Luke’s Division
745 (20)
St. Vincents Hospital & Medical of NY 748 (21) Veterans Administration Hospital 724 (10)
Beth Israel Medical Singer Division 718 (04)
  • (Number in Parenthesis indicates FDNY Hopital Number)
  • ‡ indicates trauma center designation

BNI Operatives: Situationally aware.

As always, stay safe.

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2 Responses

  1. Thanks Lina for this hospital list, good advice here.
    SJ-Grand

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