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<br />Mr. Robert T. Herrera <br />February 4, 1992 <br />Page 5 <br /> <br />. <br /> <br />. <br /> <br />(c) A pretrial report approximately one month before trial, setting forth a <br />supplement to the liability exposure report that includes: <br /> <br />(i) A summary of plaintiffs medical records, if applicable; <br /> <br />(ii) A summary of plaintiffs claimed monetary damages; <br /> <br />(ill) A brief discussion of the facts and legal issues in dispute; <br /> <br />(iv) A list of the witnesses the City intends to call at trial along with <br />a brief summary of their anticipated testimony; <br /> <br />(v) A list of the witnesses that the plaintiff is expected to call at <br />trial and a brief summary of their anticipated testimony; <br /> <br />(vi) The special issues that it is anticipated that the jury will be <br />asked to answer; <br /> <br />(vii) Possible problems in the presentation of the City's case, <br />including misssing witnesses or evidentiary problems; <br /> <br />(viii) An assessment of the probability of an adverse award and the <br />range of probable recovery; <br /> <br />(ix) A settlement recommendation and, when appropriate, a request <br />for settlement authority. <br /> <br />In some instances, a court-required pretrial order will contain most of the <br />information set out above and a copy of that order along with a supplementa- <br />ry report containing the remaining information sought will suffice. <br /> <br />During the course of our representation we will provide the City Attorney, the <br />Human Resources Director and any other representative you designate with copies of all <br />important pleadings or correspondence that we prepare on behalf of the City and will <br />continue to keep you advised of any new developments. If you prefer that we follow some <br />other reporting format, please let me know and we will be happy to do so. <br />