Ep. 51 - Understanding the Discovery Process

Brooke Jones: I want to make things as easy as I can for people because I know with going through a lawsuit, even with being hurt, you’re dealing with a lot of paperwork; you’re having to fill out forms all the time. The last thing I want to do is have you fill out yet another form. So I try to answer as much as I can for people.

David Craig – Host: I’m attorney Dave Craig, managing partner and one of the founders of the law firm of Craig, Kelley and Faultless. I’ve represented people who have been seriously injured or who have had a family member killed in a semi or other big truck wreck for over 30 years. Following the wreck, their lives are chaos. Often, they don’t even know enough about the process to ask the right questions. It is my goal to empower you by providing you with the information you need to protect yourself and your family. In each and every episode, I will interview top experts and professionals that are involved in truck wreck cases. This is After the Crash.

Welcome, everybody, to another episode of After the Crash, the podcast. I am extremely excited today to have Brooke Jones as our guest. Brooke is a fantastic paralegal who works in our office at Craig, Kelley and Faultless, and she handles the area of discovery. That’s an area that a lot of folks ask me about. “After a crash, what happens? How’s the lawsuit processed? What is done?”

Probably nothing has more questions and litigation than discovery. “Why do I have to answer this? Why do I have to give these documents?” And all those types of things. And so, we thought we would dedicate one episode of After the Crash to discovery, so that people could find out what are our interrogatories, requests for admissions, requests for production, what do we have to do? Should we be concerned? And there’s no better person to do that than the person who I trust, and have [trusted] for years, to answer our discovery form on behalf of our clients. So, welcome, Brooke, to the podcast.

Brooke Jones: Thank you. Thank you for having me.

David Craig – Host: Let’s start off, tell us a little bit about yourself. Tell us about where you went to school and how long you’ve been a paralegal, and tell us a little bit about your family. Just tell us a little bit about yourself.

Brooke Jones: Okay, yeah, so I’m Brooke Jones. I am originally from Illinois. I graduated from the University of Illinois with an English degree, of all things, but I always — even in high school, I was interning at law firms —and that was kind of always where the end goal was for me. So, right out of school, I got a job at a law firm in Illinois where we actually did a lot of family law, criminal law, probate. I didn’t really touch personal injury. I think the entire, almost four years I was there, I maybe did one or two. And then my husband, Nick, his job got transferred here to Indianapolis, so that is how I ended up here. I wanted to do something different and I saw the job offer for a discovery paralegal and I was like, “I do discovery for family law. I can do that.” And that’s how I ended up here. Family-wise, like I said, I’m married, my husband’s name is Nick, and I have a three-year-old son named Harry, Harry Jones, who comes around here a lot.

David Craig – Host: Harry’s a lot of fun.

Brooke Jones: Oh, yeah. Always wants to go to mommy’s work to get the donuts. So, he’s a big fan, a big fan of the office.

David Craig – Host: How long have you been doing discovery for Craig, Kelley and Faultless?

Brooke Jones: Six years.

David Craig – Host: Tell us a little bit, I guess tell us what you do with respect to discovery.

Brooke Jones: Okay, so yeah, whenever we get written discovery in for plaintiffs, which would be our client, I initially go through the document for them. So all the easy questions, the “what’s your name, what’s your address, what’s your date of birth,” kind of those simple things I go through, fill it out for them just so they’re not answering the same things over and over again.

I want to make things as easy as I can for people because I know with going through a lawsuit, even with being hurt, you’re dealing with a lot of paperwork. You’re having to fill out forms all the time. The last thing I want to do is have you fill out yet another form. So, I try to answer as much as I can for people. Especially when they ask the questions like, “What’s the name of the police officer that responded to the scene?” The client may not know that, but I have access to that information from the police report.

Once I get a draft done, that’s whenever I link up with the client and tell them, “Hey, this is who I am, this is what I do, let’s fill in some blanks together. Let’s go through some answers together. Once I get everything filled out, I’ll send it to you for final review.” Because like I said, the last thing I want them to do is have to sit down and fill out a form for hours and hours whenever I can just get them a semi-final product that they can look at in its entirety.

David Craig – Host: I think most people don’t even know anything about discovery because they probably have never been in a lawsuit, they’ve never been hit by a semi, they have no idea what’s involved. And it can be a lot, because, like you said, clients are going through a lot. It can be like, “Well, these people are prying.” So, I guess, let’s start off with [defining] discovery.

I mean, the three types of discovery that we see are interrogatories, requests for production, and sometimes requests for admission (although technically not a discovery tool, it’s often used as a discovery tool). So, let’s start off talking about what interrogatories are.

Brooke Jones: Interrogatories are questions that they [clients] need to provide answers to. So, it can encompass anything, like I said initially, just that identifying information: who are you, where do you live? Just that basic information of, who is this person? And then they ask questions, of course, about the accident. What happened? The narrative is a big question that we have to answer. Why are we here? What was the big cause? What’s the problem? And then it breaks down into your damages. How were you injured? What parts of your body were injured? Did you receive medical treatment? With whom? How about the medical bills? Are there any liens?

And they break down things like a wage loss claim for those who are injured and they’re unable to work, are you claiming that you lost wages? So a lot of things that, from a client looking at it, are relevant to the case: a breakdown of why are we here, what are we claiming? What are our damages?

In the interrogatories, they do ask questions that, at first glance, kind of appear like they aren’t relevant. A big one that they always ask is prior medical history. And so we do — I’m kind of going off on a little bit of a tangent here — from the very beginning, one of the first things we do, even before we’re served with discovery, is we schedule a prior medical history call with our clients and we get around 10 to 15 years of medical history. I know a lot of people kind of [feel like] right off the bat we’re asking a question of, why are you asking this? This doesn’t really seem like it’s relevant, but it does come up in discovery. So we get that. So that’s interrogatory, is asking a question, providing an answer.

David Craig – Host: These are extraordinarily important, and people don’t always recognize that. So at the end of these, you have to sign these, the client does. You have to sign these under the penalties of perjury. And so if you lie, then that can be used against you and destroy your case. Now most people aren’t going to lie, but sometimes they forget things, and they don’t remember something. And so they state an answer that is incorrect, not because they’re trying to deceive anybody, but because they’ve forgotten something. And that’s why it’s so important that we get the prior medical records and go through all that so that we can remind you, “Hey, did you remember this or that?” Because you go to the doctor and, let’s say it was 10 years ago or nine, eight years ago, and you may have gone in there for a routine checkup, but while you were there, you mentioned, “By the way, I slept funny last night and my neck hurts.”

Now you don’t remember that because you didn’t get any follow-up treatment, you didn’t have any problems, but they may have written it in their medical records that you complained of neck pain. And all of the sudden now you’re in a car wreck, and a semi hits you, and now you have a really bad neck injury. And so, you’re claiming this neck injury, a herniated disc surgery or whatever, is related to this wreck, which it is. But you may not remember that, eight years ago, you told a doctor that your neck hurt. And if you say, “I never have any prior complaints of neck pain,” and then the other side gets your records and they see that prior neck complaint, it looks like you’re lying about something that you’re not lying about. And that can ruin your case.

The first thing is you want to be thorough. Number one, you want to be honest, which I find that very rarely is a problem, but you want to be honest. The second thing is, is that you don’t want to answer something you don’t remember. You want to look back and double check and make sure you know the answers. It’s just like if the police report, like Brooke just said, if they ask you who the police officer is and you guess, “Oh, it’s Joe Smith.” Well Brooke can look and make sure it is Joe Smith or maybe it’s Joe Smithereen or whatever. And so Brooke can change it. She’ll look and she’ll say, “Hey, the police report says this. Are you sure of that?” And provide that information. But you’re answering those interrogatories. And I’ve seen interrogatories used at trial where someone made a mistake, and we’ve used it before against the defendants or the lawyer answers something for the client and it was incorrect, or the client didn’t tell us something or said something inaccurate in the interrogatories, and it comes back to haunt them.

So, you want to be very careful to do that. But I think one other thing Brooke mentioned, and I’ll let her talk about, is that, people sometimes resent…

So you’re in a wreck, a semi hits you on I-465 in Indianapolis, and now you’re injured to no fault of your own. Then they start asking you for medical records for your prior 10 years, and people get frustrated. It’s like, “Well, wait a minute, this broken leg or my neck, I mean it clearly came from this wreck. Why do I have to tell them my whole…” People get frustrated with that.

Brooke Jones: Oh, they absolutely do. I understand. If I was hurt, the last thing I would want is people digging into my medical history. So I definitely understand, but unfortunately, we do have the burden of proof. I always tell people, I would rather give them everything that they ask for just so it doesn’t look like we’re trying to hide anything or conceal anything because, if we start trying to keep things close to the chest and maybe just being vague or not being dishonest, but maybe not being completely honest, that can turn around and that can hurt your case, and that’s the last thing you want to happen. So it’s better just to be completely forthcoming.

Like you’ve said with the neck thing, I’ve definitely had people get upset with things like that because “I don’t want them to think my neck has been a problem.” I just try to tell them, I’m like, “Well, like you said, this is something that popped up one time. You weren’t scheduled to have any follow-ups, you weren’t scheduled to have PT. It was just a one-time thing that was mentioned and it was never mentioned again.” Something like that in the long run isn’t going to be a huge issue for you. It’s better just to list it out and be honest.

David Craig – Host: Absolutely. The only thing that can hurt us is not knowing something because, quite frankly, our job is to win with what the facts are, no matter what the facts are. And a pre-existing condition, even. Let’s assume you had a prior neck problem, and you did get treated for it, and you’ve had neck problems, that doesn’t mean if it is made worse by a wreck, then you’re entitled to be compensated for the worsening of your condition. It’s the aggravation of a pre-existing condition. As we get older, we have degenerative spines or we start getting arthritis, and so as we get older, a lot of us are going to have issues.

Well, that makes sense, but it also makes sense that the more issues you have the easier you are to hurt. And the easier you are to hurt, the harder you are to fix. So, the more pre-existing conditions you have can make your case a lot worse than somebody who’s 24 years old, who has a perfectly fine neck. And you’re 65 years old and you’ve got arthritis in your neck. The same wreck that doesn’t hurt the 24-year-old may really make your life miserable as a 65-year-old.
And the law recognizes that, you take your plaintiffs as you find them. Whatever the difference is in how you are before versus how you are after is something that you’re entitled to recover for. So, no matter what you have in your medical records, it cannot hurt you if the wreck has made it worse. The only thing that can hurt you is if you don’t tell or you don’t disclose it. And, unfortunately, some people just don’t remember it. It was a minor mention. I mean, I’ve seen dental records where they say that they’re having headaches, and it turns out that the headaches after the wreck are due to a traumatic brain injury. They’re nothing like the sinus headache that they complained about at the dentist’s office. So if you disclose that, it doesn’t hurt you. If you don’t disclose that, it looks like you might be hiding it. So Brooke’s job is to go through — we request all the prior medical records — and make sure that we’re as thorough as possible because we would rather give too much information, even though it seems like an invasion of your privacy, we would rather give too much information.

Now, I think, one other point I would want to make here is that, just because it’s discoverable, meaning Brooke has to disclose it on your behalf, doesn’t mean that it’s relevant. It doesn’t mean that they get to use it at trial. So, if you have some prior issues that have nothing to do with your current issues, then we can ask the judge to not allow the other side to talk to the jury about it. And so maybe it’s something that you had some kind of disease that you don’t want to talk about. Well, the reality is, they won’t get to talk about it if it has nothing to do with your injuries. But again, our rule of thumb in our firm is we’d rather disclose it and then ask the judge not to allow it to be admitted than not to disclose it and then have them pop it or try to surprise us with it at trial.

Brooke Jones: And by disclosing it in discovery, it gives you more time to… If it’s something where more questions need to be asked, if we disclose some kind of injury or a complaint of pain, there’s more time to ask additional questions about it. So, if the opposing says, “Well, hey, let’s talk more about this record that I found.” Well, you could get the chance to talk about it more. The opposing may realize, “Oh yeah, this isn’t even relevant at all,” and then everyone can move on and just focus on the facts of the case.

David Craig – Host: I think we do, we try to be thorough, and we try to answer these interrogatories. Interrogatories, other questions, I guess there’s a couple key ones. Your prior medical records or prior medical injuries are an important thing. What other one do you think is pretty important?

Brooke Jones: Your injuries, of course. So what are we claiming in the case? Really got to nail that down, and that is one — something we haven’t really touched on — is that you can do supplements to your discovery. If we forgot to include something and you remember a couple of months down the road, I’ve had people call me and be like, “I completely forgot about this one random thing.” Timing-wise, most of the time it’s not an issue to be able to do a supplement and pretty much just tell the opposing counsel like, “Hey, we forgot to include this.” Or, “We need to update an answer, here’s this.”

So, again, for the injuries for the case, depending on whenever we get served with discovery, that can be one that we have to pay attention to. That becomes important, and we have to supplement because, two months into a case, you may not have the entire story of what your injuries are and what your recovery period is. Will you require surgeries and additional treatment for years down the road or potentially for the rest of your life? So, the injury is definitely a big one.
Something I touched on earlier is the narrative of what happened. A big one for that, I would say, is whenever we answer it, you put down what you remember. We do deal with a lot of people with traumatic brain injuries, and they may know what happened just based on talking to people, they’ve seen maybe the police report, they talked to their family, but they may not know. So, if you’re asking honestly, “Hey, how did the accident happen?” Saying you don’t recall, if you truly don’t recall, is a fair answer. I know that’s been one that has come up a lot, is people want to say, “Well, hey, this is what happened.” The facts of the case is what happened, but do you actually know that? Do you actually remember that? Maybe a no. You may not recall, based on what your injuries are. One that comes up too, criminal history, but there’s only certain convictions that can be admissible in the court. But I would say that’s, in my opinion, the ones we really focus on would be injuries, narrative, prior medical history.

David Craig – Host: Yeah, and I think, with respect to injuries, you made a good point is that sometimes we have to answer the interrogatories before we really know what the full extent of the injury is. So somebody, again, if they’re complaining of neck and shoulder, sometimes they think it’s the shoulder that’s causing the problems, sometimes they think it’s the neck, and sometimes you have to go through therapy or injections or then ultimately MRIs to figure out, is it the neck that’s causing the problem or is it the shoulder? If it’s the shoulder, maybe there’s a torn rotator cuff or if it’s the neck maybe it’s radiating from one of the discs down into your shoulder and into your arms. We may not know that until after. So we would just basically say, my neck and shoulder are injured, and then we may have to supplement it down the road to say there was a rotator cuff tear and then there had to be a surgery. So, we can supplement and we can add, it’s just we try to be as thorough as we can.

Brooke Jones: Yeah, the first time around.

David Craig – Host: And, again, we get the medical records. You may have fractured ribs, and anybody that’s had fractured ribs knows that that pain is extraordinary. So, at the hospital, you may be complaining of your ribs hurting the worst, and you may not even be noticing anything else because you’re having trouble breathing, maybe it punctured a lung, but the fact is you may also have a neck injury or a leg injury that’s just not as painful. And so you may not even mention it because you can’t breathe and the pain in your chest is horrific, or sternum fractures are terrible. Sometimes we see that a week later or two weeks later or a month later, when the pain starts to subside from the chest, we then start seeing other injuries, and so we have to add those as well.

You mentioned criminal backgrounds. I mean, sometimes we have clients that may have had a criminal run in their lives. It’s not something they’re proud of, it’s not something they want to talk about and they think it’s prying. It’s like, “Well, this doesn’t have anything to do [with the case]. If a semi runs a stop sign and hits me, what does it matter that I had a criminal violation or a conviction in the last five or 10 years?”

And I would say that it probably doesn’t. But again, it’s one of those things that we want to disclose it rather than not disclose it. We don’t want to have something that should not matter, matter. And so the way we do that is we disclose it and then we tell the judge, “Judge, this doesn’t have anything to do with anything and it should not be used at trial.” And there’s only certain crimes under a certain period of time that, both in federal and state courts, are admissible. And so if it doesn’t fit those, then they’re not admissible. We can keep it out, but we still disclose it because the rule of discovery is, is not what’s relevant. You don’t have to disclose just what’s relevant. You have to disclose anything that may lead to the discovery of relevant information. So, by asking somebody, “What crimes have you committed?” That may lead to the discovery of one of the ones that is admissible, it is relevant. So, you can ask that question.

We would say you can limit it, but again, from our perspective, we don’t worry about limiting or playing games. We disclose it, and then we fight to keep it out. The other thing to remember is that this stuff is not shared, and so you’re not going to have to worry about things becoming public in a lawsuit, so it would only become public if it’s actually deemed admissible and then used at the trial. So you shouldn’t be afraid to disclose something. Never, whether you’re working with the law firm of Craig, Kelley and Faultless or you’re working with another personal injury law firm, never be afraid to disclose anything and everything to your lawyer. Your lawyer cannot protect you if she or he doesn’t know something. So please, if you don’t learn anything else from this, and you’re watching this and you’ve been injured, the thing I would want you to learn is to make sure you tell your lawyers anything and everything. Let them decide what to do with it.

Brooke Jones: Absolutely.

David Craig – Host: Requests for production. Explain what a request for production is.

Brooke Jones: That one is exactly what it sounds like. They are requesting that we produce certain documentation. What is always asked, they’re always going to ask for your medical records, and they’re always going to ask for your medical bills. They are going to ask, “Is there a police report? Any 911 audio? Any state witness statements of anybody that was around?”

They’re going to ask for photographs. And they break that down, photographs. They want photographs of any vehicles involved, and they want to know, “Do you have any photographs of your injuries?” So those are kind of the main ones that they ask for. If you’re making a wage loss claim, they will ask for documentation from your employer that backs up that wage loss claim to show the time that you missed. What I’m seeing a lot more of these days is they are asking a lot about social media. Did you post anything about the accident or the defendant, your injuries, your treatment — anything online, that’s becoming more and more relevant from what I see in discovery.

So that, like I said, they asked us to produce a bunch of things. And a lot of the stuff that I listed off, we already have. We always get your medical records, we get your medical bills, we have the police report, but there are times where I need help getting some documentation because if they do ask, [for example] a picture of your driver’s license, so I’ll have to work with the client on getting pictures of the driver’s license.

With social media, we may not have it. So, “Hey, I need you to go to your account, screenshot the posts if there are any.” So there is some back and forth with that as well of getting me everything that I need. And sometimes some things take longer, especially when it comes to wage claims. One of the things we have to produce is tax returns. Some people just don’t have their tax returns on hand. So I say, “Hey, work on getting that over to me so we can get that produced,” if you’re making a wage claim.

David Craig – Host: One of the things to remember is that, if we’re going to make a wage claim, we have to document it and we have to prove it. Now, we may lose, let’s say you can’t ever go back to work, so you’ve got a catastrophic injury, you can’t ever go back to work. Then what we have to do is we have to hire an expert and we hire a vocational rehabilitation expert, and that person will tell us what the loss of future earnings are, but that person’s going to need tax returns. They’re going to need a history of your wages. So, a lot of the documents that we have to produce, that Brooke’s talking about, are documents that we’re going to need anyway to show our experts. And again, we want to hire the right people and give them the right information so that we can get an accurate picture so the jury has an accurate picture of what the real losses are in a particular case.

And so, it’s not prying. If you’re going to ask for loss of future earnings, then you should be willing to talk about how much money you’ve made in the past, your education level, what degrees you have, your employment history. There’s a whole bunch of things that become suddenly relevant or maybe relevant that aren’t relevant or won’t lead to discovery relevance if you’re not making a wage claim. But if we are making a wage claim or loss of future earnings, then we have to go through the hurdles of getting those documents. Some stuff does take time, like Brooke said.

One thing to remember, though, is that our goal — whether it’s answering interrogatories, answering requests for production or admissions —is to answer this stuff as quickly as possible because we’re trying to move your case along as fast as we can. Every plaintiff law firm should be the same. They should be trying to move their cases along as fast as possible. So, number one, they should be looking and getting a lot of this information ahead of time. We do background checks on both our client and the plaintiff and the defendant as soon as we get hired. We requests, like Brooke said, we do a prior medical history call, as soon as we get hired. We start requesting those medical records. We request the treatment records from after the wreck.

So, we’re gathering information. If there’s a wage claim, we’re going to be asking you for this stuff. So the goal is to get this stuff put together as quickly as possible for you so that we can keep moving your case towards, ultimately, a trial if necessary, or a mediation or settlement conference. And so sometimes you get clients who are slow to react or slow to answer and it’s like, “Boy, you’re just shooting yourself in the foot.” I know it’s a hassle. I know it’s hard to sit down and put all the time and effort necessary, but we’ll make it as easy as possible, as I think all law firms do, but the quicker you get us the information, the quicker we can move your case towards a favorable resolution. So, one other thing we sometimes see are requests for admissions. Do you see those very often?

Brooke Jones: Not often. I maybe get one set every couple months. We don’t get them often for our clients to answer.

David Craig – Host: Requests for admissions are when — the lawyers actually answer these rather than the client — but the lawyers may discuss it with their clients. It’s actually asking to admit certain things. So we serve requests for admissions on our cases. We make the defendants say or admit things. And so we may say, “Admit that you were driving this car. Admit that you had insurance limits of X number of dollars. Admit that you ran a stop sign.” The theory behind it is if they admit it, it reduces the number of items that you’re fighting over. So if they admit it’s their fault, you no longer have to fight over whose fault it is. Admit that our client didn’t do anything wrong that caused or contributed to the wreck. If they admit that, then that makes it quicker and it helps to speed up the process. So, sometimes law firms that defend these cases will serve us admissions. Not as often as we do; we serve them on every case. But again, it’s not something we see the defense use that often.

Brooke Jones: No, not often at all.

David Craig – Host: So, let’s talk about, sometimes you get a supplemental set of discovery. Occasionally on cases if they go long enough, you have to actually answer a second set, correct?

Brooke Jones: Yeah, that’s correct. A lot of times, they typically just ask you kind of a blanket statement of, “please go through your prior discovery and supplement anything that is out of date.” So then we’ll take a look, because obviously some things won’t need changed. Your work history is not going to change, your educational history, it’s not going to change. There’s only certain questions we’re going to have to go through to make sure that they’re completely up-to-date. But sometimes after they look at the first set of discovery and what we send to them, that may potentially prompt more questions. So they may send another set of discovery in order to elaborate on something else, or they may see something in your prior medical records and it may prompt more questions. If you had a prior personal injury lawsuit, they may ask, “Let’s get some more information about that.” So the biggest thing I would say that we get is just to ask, after so much time has passed, is just to ask to make sure everything is up-to-date.

David Craig – Host: The quicker we can respond, the quicker we move your case. And every law firm does it a little bit differently, but the way we do it is — Brooke has done this for years now. She’s worked with the attorneys; we showed her, here’s how we like to see these answered. And then with us, we like to provide more information as quickly as possible so the insurance company knows, has the information that they need to value a case.

And it makes sense when you think about it, even though most clients [say], “I don’t feel like I should have to give my medical records. I shouldn’t have to tell them all my…” But you think about it, let’s say that you had carpal tunnel. You had carpal tunnel and you were treating for it up until the end of the month. And at the end of the month, the doctor tells you that you need surgery for your carpal tunnel. Well, then the first of the next month you have a wreck, and you claim that you have carpal tunnel, and you claim you never had problems.

Well, that’s not fair. That’s not right. It’s not honest. And so why would an insurance company not need to know what your prior medical records are? The insurance company is entitled to look and see, make sure that the problems you’re claiming are the ones related to the wreck. The sooner we do that, the better off we are, and the better we can deal with it. But the way we do it, as Brooke [said], we’re very proactive. We’re proactive getting the records, proactive getting background checks, very proactive trying to help so we can have information we can talk to our clients about.

Our clients give us their version of how the wreck happens, that’s completely up to them. What do they remember? And then we put all that together, and then a lawyer reviews it. Brooke then has to work with one of us, and we then review it and make sure that it’s accurate and it’s complete. And then we make sure the client reviews and make sure the client is comfortable and make sure everything’s being truthful. Everything is what the client [said], so we’re not answering for the client. The client looks at it, reads it: “Oh yeah, that’s accurate.” And the client signs the affirmation saying it’s true and accurate to the best of their recollection. Then, we’re comfortable sending that out. I’ve been practicing for 38 years, and I can tell you that by answering discovery completely, honestly, it does nothing but help.

Giving more information than even what they want… they know you’re not playing games. They know that, no matter what, we’re going to win the case based upon the facts of the case — not on something else. And I think by doing that year after year after year, our firm has developed a good reputation of, “Hey, you can count on these guys.” Because, like Brooke said, one of the things they asked in the request for production of documents is medical records. And so we supplement those as we go. So as our client gets treatment, we don’t wait until there’s a second set because we have a duty under the rules to continue to supplement. And so we supplement as we go, and I’ve heard defense lawyers say that’s very helpful to them. It helps them value the case. It helps them understand the case. So by providing the information, it actually helps you. It doesn’t hurt you. So Brooke, so how do you like working for the law firm of Craig, Kelley and Faultless?

Brooke Jones: It’s okay, it’s all right. No, it’s great. I wouldn’t have stayed around this long if I didn’t love it. I know I’m helping people. They deal with a lot of people in our firm. I’m the one that’s asking the prying questions. I’m the one that’s digging in on them. So I try to just be as personable and friendly and try to just make it as easy as possible. I’m nice. I’ll crack a couple jokes with you. I know this is kind of a painful process, but I’m here to try to make it a little bit better. But no, everybody here’s great. We are all here to help. If you need anything, we’re just here to make things a little bit easier in a really hard time in your life.

David Craig – Host: The beauty of it is that we’re trying to make a positive difference in the lives of our clients, and we can do that through people like Brooke. I’m proud of her, and I really enjoy working with Brooke. She does a great job at what she does, and it is not easy. It’s not easy asking clients for information. People, they just feel put out. They feel like, “Okay, it’s prying. It’s not my fault. I wasn’t in this… Why are we asking this stuff?” And it’s just the normal pattern. It’s just in every single case there’s going to be discovery served, and it’s just the way it works. That’s the way our system is set up. Rather than fighting it, working with Brooke or whoever in the law firm that you have that does that, it’s better to cooperate and be helpful.

Brooke Jones: Yeah, absolutely.

David Craig – Host: Anything else, Brooke, about discovery you want to talk about or share?

Brooke Jones: That’s all I got. That’s all I got. So no, if you have a case that goes through the litigation process, you will be dealing with me. So yeah, I’ll look forward to working with you, that just make things a little easier.

David Craig – Host: All right, well thanks for being a guest on After the Crash, the podcast.

Brooke Jones: Well, thank you for having me. I appreciate it.

David Craig – Host: This is David Craig, and you’ve been listening to After the Crash. If you’d like more information about me or my law firm, please go to our website ckflaw.com. Or, if you’d like to talk to me, you can call 1-800-ASK-DAVID. If you would like a guide on what to do after a truck wreck, then pick up my book, Semitruck Wreck: A Guide for Victims and Their Families, which is available on Amazon, or you can download it for free on our website, ckflaw.com.