How Do I Document My Personal Injury Conditions?
You may want to document your condition by keeping a log or writing notes about your symptoms and pain level. However, if you do so, be aware that anything you write may ultimately be revealed in court. In order to prevent this, there are a couple steps you should take to safeguard your communication with us.
First, make sure to write “privileged attorney-client communication” at the top of any notes you share with us. Your confidential communications with your attorney are strictly protected by the law. Stating this explicitly on your notes can help protect it from being disclosed in court.
Second, do not share written information with any third party or even discuss its contents. Doing so can turn a confidential communication with your attorney into a document that must be publicly disclosed.
Third, do not bring these notes to a deposition or another proceeding in order to refresh your memory. The rules of evidence state that such materials must be disclosed, and the opposing attorney can and will ask you for a copy of any notes you are using.