DISPARTI LAW GROUP, P.A.
www.DispartiLaw.com Mailing Address: P: (312)506-5511
121 W Wacker Dr Suite 2300 F: (312) 846-6363
Chicago, IL 60601
October 11, 2022
SENT VIA FIRST CLASS US MAIL
And VIA EMAIL Humphreysjames97@gmail.com
James Humphreys
3750 W. Cermak Road
Apt. 1
Chicago, IL 60623
Re: Litigation of Your Personal Injury Case
Dear Mr. Humphreys:
I would like to introduce myself as the attorney that will be handling the litigation portion of your case.
Please be advised that it is very important to keep my office informed if your phone number, email address,
or home address changes at any time throughout this process. It is important that I am able to get ahold of
you throughout the remainder of your personal injury case. Failure to inform our office of any changes to
your contact information will cause delays in your case.
I have enclosed multiple documents requiring your signature. The first document is a HIPAA order that is
required in Cook County. Please sign the HIPAA order where your signature is indicated. The second
documents are signature pages for your discovery documents. The last document is a questionnaire packet
which will require your completion, this is the only document that will not require your signature. Please
sign all of these documents and send them back to my office in the pre-paid envelope that I have provided.
Photographs, medical bills, medical records, or anything else that you believe may be useful as evidence in
your case, should be sent to our office right away.
Throughout the duration of your case, my Paralegal, SAMUEL FELDE, will be contacting you. If you have
questions at any time, he is your best point of contact. He can be reached directly at (312) 506-5511 Ext.
262 or via email at samuel@dispartilaw.com.
Very truly yours
DISPARTI LAW GROUP, P.A.
Jonel Metaj
JM/sjf
PRIVILEGED AND CONFIDENTIAL
ATTORNEY-CLIENT COMMUNICATION
ATTORNEY WORK PRODUCT
PRELIMINARY DISCOVERY QUESTIONS
• Please review each question carefully and provide as much information as possible in response to each.
It is important for your case that these answers include as much detail as possible. Please don’t leave
any questions blank.
• Once we received your responses, we will type the answers to the questions and include responsive
information from the medical records and other information that we have in our file.
• Please do your best to return these answers to us (in the self-addressed envelope) within two weeks.
*****
1. State your full name, as well as your current residence address, date of birth, marital status, driver’s
license number and issuing state, and the last four digits of your social security number.
Answer:
Full Name:
Current Address:
Date of Birth:
Marital Status: (circle one) Married Not Married
Driver’s License Number: State:
SS#:
Current Telephone Number: ______________________________________
Emergency Contact: ______________________________________________
Name: __________________________________________________________
Relationship: ____________________________________________________
Phone Number: __________________________________________________
Privileged and Confidential
Attorney Client Communication
Preliminary Discovery Questions
Page 2
2. Did you have health insurance at the time the accident? If so, please state the name of the health
insurance provider (e.g. Blue Cross / Blue Shield, Aetna, United HealthCare, County Care / Medicaid /
HFS, etc.), the plan number, group number and any other information that identifies the health care
plan. If possible, include a copy of your health insurance card.
Answer:
3. State in your own words how the accident happened. What direction were you traveling and on what
street? What direction was the other driver traveling and on what street? What part of the other
vehicle struck what part of your vehicle? How did the other driver cause the accident? Attached a
diagram if necessary.
Answer:
4. Where were you coming from before the accident and where were you going? What was the purpose
of your trip (e.g. going from home to work, going from home to the store, etc.).
Answer:
5. Were you the driver of the car? If not, who was the driver? Was anyone else in the car with you at the
time of the accident? If others were in the car, provide their names, telephone numbers and where
each was seated in the car (front seat or back seat, driver’s side or passenger’s side)?
Answer:
6. Who owned the car you were in at the time of the accident? If you are the owner of the car, do you
have a repair estimate or paid repair bill for the damage the car suffered in the accident?
Answer:
7. State the full name, current residence address and telephone number of each person who witnessed or
claims to have witnessed the accident.
Answer:
Name Address Telephone #
Privileged and Confidential
Attorney Client Communication
Preliminary Discovery Questions
Page 3
8. State the full name and current residence address of each person, not named in Question No. 2 above,
who was present and/or claims to have been present at the scene immediately before, at the time of,
and/or immediately after the occurrence.
Answer:
9. As a result of the occurrence, were you made a Defendant in any criminal or traffic case? Did you get
a ticket as a result of the accident? If so, state the court, the case number, the charge or charges filed
against you, whether you pleaded guilty thereto and the final disposition.
Answer:
10. Describe the personal injuries sustained by you as a result of the occurrence. You can simply identify
the part of your body that was injured and then describe the injury.
Answer:
11. Do you still suffer any pain from the injuries that you received in the accident? Or in other words,
state whether you have recovered from the injuries you allege to have suffered in the accident. If not,
describe the nature and extent of any continuing complaint or disability and state the name and address
of health provider from whom you currently receive treatment or consult with for any ongoing pain,
complaint or disability.
[Please be specific as to any pain you still suffer. Provide details regarding what you do when
you suffer the pain (e.g. take over the counter pain relievers, rest, etc.). And identify and
describe any activities that you enjoyed before the accident that you no longer enjoy because of
the continued pain (e.g. dancing, walking the dog, playing sports, playing with children or
grandchildren, etc.)]
Answer:
Privileged and Confidential
Attorney Client Communication
Preliminary Discovery Questions
Page 4
12. State the name and address of your primary care physician or any other physician or health care
provider who examined and/or treated you within the last 10 years. State the reason for such
examination or treatment. [10 years is a long time but try your best to provide as much information as
you possibly can.]
Answer:
13. With regard to your injuries, state:
(a) The name and address of each attending physician and/or health care professional;
(b) The name and address of each consulting physician and/or other health care professional;
(c) The name and address of each person and/or laboratory taking any X-ray, MRI and/or other
radiological tests of you;
(d) The date or inclusive dates on which each of them rendered you service;
(e) The amounts to date of their respective bills for services; and
(f) From which of them you have written reports.
[We have most of this information in your medical bills and records but please provide any information you have
so that we are sure your answer is complete.]
Answer:
14. Please state the names and addresses of all hospitals and/or clinics, the amounts of their respective
bills and the date or inclusive dates of their services. [We have most of this information in your medical
bills and records but please provide any information you have so that we are sure your answer is complete.]
Answer:
15. Were you employed at the time of the accident? If so, as a result of your personal injuries, were you
unable to work? If so, state:
(a) The name and address of your employer, if any, at the time of the occurrence, your wage and/or
salary, and the name of your supervisor and/or foreperson;
(b) The date of inclusive dates on which you were unable to work;
(c) The amount of wage and/or income last claimed by you; and
Privileged and Confidential
Attorney Client Communication
Preliminary Discovery Questions
Page 5
(d) The name and address of your present employer and you wage and/or salary.
[If you are making a claim for lost wages, please provide your state and federal tax returns for the
year before, the year of, and the year after the date of the accident. Example: If your accident
occurred in 2017, you will need to provide your tax return for 2016, 2017, and 2018.]
Answer:
16. State any and all other expenses and/or losses you claim as a result of the occurrence. As to each
expense and/or loss state the date or dates it was incurred, the name of the person, firm and/or
company to whom such amounts are owed, whether the expense and/or loss in question has been paid
and, if so, by whom it was so paid, and describe the reason and/or purpose for each expense and/or
loss.
Answer: [Here is a sample answer.]
In addition to pain, suffering, loss of a normal life, and disabilities, Plaintiff will be compelled to
expend and become legally liable for large sums of money for medical and surgical services,
nursing care and attention in and about endeavoring to become healed and cured of her injuries.
Plaintiff will also be prevented from attending to her usual affairs and duties and has thereby lost
and will in the future lose large sums of money which would otherwise have accrued to Plaintiff.
Is there anything you want to add to the answer?
17. Had you suffered any personal injury or prolonged, serious and/or chronic illness ANY TIME
BEFORE THE ACCIDENT? If so, state when and how you were injured and/or ill, where you were
injured and/or ill, describe the injuries and/or illness suffered, and state the name and address of each
physician, or other health care professional, hospital and/or clinic rendering you treatment for each
injury and/or chronic illness.
Answer:
18. Are you claiming any psychiatric, psychological and/or emotional injury as a result of this occurrence?
If so, state:
(a) The name of any psychiatric, psychological and/or emotional injury claimed, and the name and
address of each psychiatrist, physician, psychologist, therapist, or other health care professional
rendering you treatment for each injury;
(b) Whether you had suffered any psychiatric, psychological and/or emotional injury prior to the date of
the occurrence; and
Privileged and Confidential
Attorney Client Communication
Preliminary Discovery Questions
Page 6
(c) If (b) is in the affirmative, please state when and the nature of any psychiatric, psychological and/or
emotional injury, and the name and address of each psychiatrist, physician, psychologist, therapist or
other health care professional rendering you treatment for each injury.
[Here is a sample answer.] None other than the ordinary mental suffering that accompanies
personal injury.
Answer:
19. Do you suffer from headaches since the accident? Are you forgetful or do you get disoriented (e.g.
you misplace things, like your keys, you go somewhere and forget why you went there)? Do you get
dizzy or lose your balance more easily? Do you sometimes feel sick to your stomach or vomit?
Answer:
20. Have you suffered any personal injury or prolonged, serious and/or chronic illness AFTER THE
ACCIDENT BECAUSE OF A DIFFERENT ACCIDENT OR ILLNESS? If so, state when you
were injured and/or ill, where and how you were injured and/or ill, describe the injuries and/or illness
suffered, and state the name and address of each physician or other health care professional, hospital,
and/or clinic rendering you treatment for each injury and/or chronic illness.
Answer:
21. Have you ever filed any other lawsuits for your own personal injuries? For any other lawsuits, state
the nature of the injuries claimed, the courts and the captions in which filed, the years filed, and the
titles and docket numbers of the suits.
Answer:
22. Have you ever filed a claim for and/or received any workers’ compensation benefits? If so, state the
name and address of the employer against whom you filed for and/or received benefits, the date of the
alleged accident or accidents, the description of the alleged accident or accidents, the nature of your
injuries claimed and the name of the insurance company, if any, who paid any such benefits.
Answer:
Privileged and Confidential
Attorney Client Communication
Preliminary Discovery Questions
Page 7
23. Did you or anyone else take any photos of:
a. The cars;
b. The accident scene; or
c. Your injuries?
If so, please provide copies of these photos.
Answer:
24. Have you (or anyone acting on your behalf) had any conversations with any person at any time with
regard to the manner in which the occurrence complained of occurred, or have you overheard any
statements made by any person at any time with regard to the injuries complained of by Plaintiff or to
the manner in which the occurrence complained of occurred? If the answer to this question is in the
affirmative, state the following:
(a) The date or dates of such conversations and/or statements;
(b) The place of such conversations and/or statements;
(c) All persons present for the conversations and/or statements;
(d) The matters and thing stated by the person in the conversations and/or statements;
(e) Whether the conversation was oral, written and/or recorded; and
(f) Who has possession of the statement if written and/or recorded.
[Did you talk to the other driver after the accident? Did you talk to an insurance company
representative about the accident? If yes, tell us when you spoke to the person, who you spoke
to and what was said.]
Answer:
25. Do you know of any statements made by any person relating to the occurrence? If so, give the name
and address of each such witness, the date of the statement, and state whether such statement was
written and/or oral.
[Do you know if anyone else talked to an insurance company about the accident?]
Answer:
26. Had you consumed any alcoholic beverage within twelve (12) hours immediately prior to the
occurrence? If so, state the names and addresses of those from whom it was obtained, where it was
consumed, the particular kind and amount of alcoholic beverage so consumed by you, and the names
and current residence addresses of all persons known by you to have knowledge concerning the
consumption of the alcoholic beverages.
[An answer to this question is required even if you were not the driver.]
Privileged and Confidential
Attorney Client Communication
Preliminary Discovery Questions
Page 8
Answer:
27. Have you ever been convicted of a misdemeanor involving dishonesty, false statements or a felony?
If so, state the nature thereof, the date of the conviction, and the court and the caption in which the
conviction occurred. For the purpose of this question, a plea of guilty shall be considered a conviction.
Answer:
28. Had you used drugs or medications within twenty-four (24) hours immediately prior to the
occurrence? If so, state the names and addresses of those from whom it was obtained, where it was
used, the particular kind and amount of drug or medication so used by you, and the names and current
addresses of all persons known by you to have knowledge concerning the use of the drug or
medication.
[This is not intended to invade your privacy, but this question is permitted, even if you were not the
driver.]
Answer:
29. List the names and addresses of all other persons (other than yourself or persons heretofore listed) who
have knowledge of the facts of the occurrence and/or the injuries and damages claimed to have
resulted therefrom.
[Is there anyone who knows something about the case that you have not yet identified?]
Answer:
30. State whether you owned a cellular phone, smart phone or similar device at the time of the accident. If
you did have a cell phone at the time of the accident:
a. Who was the carrier (Verizon, Sprint, AT&T, T-Mobile, etc.)?
Answer:
b. What was the telephone number?
Answer:
Privileged and Confidential
Attorney Client Communication
735 ILCS 5/1-109 CERTIFICATION
Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil
Procedure, 735 ILCS 5/1-109, the undersigned certifies that the statements set forth in this
instrument are true and correct, except as to matters therein stated to be on information and belief
and as to such matters the undersigned certifies as aforesaid that the undersigned verily believes
the same to be true.
________________________
[Print Your Name]
________________________
[Sign Your Name]
735 ILCS 5/1-109 CERTIFICATION
Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil
Procedure, 735 ILCS 5/1-109, the undersigned certifies that the statements set forth in this
instrument are true and correct, except as to matters therein stated to be on information and belief
and as to such matters the undersigned certifies as aforesaid that the undersigned verily believes
the same to be true.
________________________
[Print Your Name]
________________________
[Sign Your Name]
