PRIVILEGED AND CONFRIDENTIAL

ATTORNEY – CLIENT WORK PRODUCT

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Sexual Molestation Case Evaluation

Case Caption:Date Prepared:

I. Background/Summary:

A. Insured:

B. Plaintiffs First and Last Name, and Gender:

C. Plaintiff’s DOB & Current Age:

D. Plaintiff’s SSN and HICN if applicable:

E. Dates of Alleged Abuse:

F. Defense Firm & Lead/Trial Attorney on this Case:

G. Plaintiff(s)’ Counsel & Lead/Trial Attorney on this Case:

H. Jurisdiction:

I. Judge:

J. Trial Date:

a. Mediation Date:

b. Settlement Conference Date:

K. Demand:

L. Authority Requested:

M. Negotiation History:

II. Detailed Description of the Claim:

Plaintiff: This section should inform the reader about all relevant information as it pertains to the plaintiff and their claim. Included should be a brief summary of all relevant deposition testimony and pertinent medical/treatment information.

Perpetrator: This section should inform the reader about the perpetrator and his/her connection to the plaintiff. Details regarding criminal history (and the outcome of any criminal proceeding), employment history (any disciplinary actions taken against the perpetrator) should be included.

III. Liability Assessment:

A. Exposure (as to all defendants, if applicable):This section should allow the reader to compare plaintiff’s overall injury with the injury allegedly caused by the insured. Included in this section should be a description of each defendant’s involvement as it relates to the plaintiff’s injury.

B. Exposure (as to insured): This section should provide the reader information as to the plaintiff’s injury as it relates to the insured. Included in this section should be a description of every incident.

IV. Medical Information:

A. Injury Alleged:This section and the subsections below should include the specific injuries claimed (ex. Post-Traumatic Stress Disorder, Decreased socialization abilities);

1. Defense Expert(s) Findings:

2. Plaintiff’s Expert(s) Findings:

B. Other Significant Medical History:

V. Damages:

A. Economic Damages:

1. Medicals (provide range and explain):

2. Lost Wages (provide range and explain): Provide plaintiff’s estimate, our economist’s estimate and the amount the jury will likely accept. If we have not retained an economist, provide an estimate of the amount that plaintiff can likely substantiate.

B. Non-Economic Damages:

1. Pain and Suffering, Loss of consortium and etc.

C. Exemplary/Punitive Damages:

VI. Exposure:

  1. Estimated High, Medium, and Low Verdict Range (provide amount as to all defendants and give supporting information based on recent verdicts): Verdict history should explain whether verdicts were upheld or struck down on appeal.
  1. Percent Chance of a Defense Verdict for Insured (provide a numeric percentage and explain basis for estimate):

VII. Other Pertinent Details to Assist in our Evaluation:

VIII. Recommended Strategy/Next Steps For Disposition of the Case:

(Including but not limited to pending motions)

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