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It is good practice, at the start of a plaintiff's case, to inquire of a potential subrogated insurer what their interest is.  A suggestion follows.

We represent (Client's name) in regard to a claim for injuries, which are being made against defendant parties arising out of the above referenced matter. Enclosed is a copy of the complaint which we have served on the defendants.

We understand you want us to recover from the defendants the amounts you paid to or on behalf of (Client= s name) , and for which amounts you claim a subrogated interest. Please respond to the following marked four items.

1. First, immediately tell us the total amount for which you seek a subrogation recovery and give us a brief summary of the type of expenses (e.g., medical, wage replacement, et cetera).
    
2. Second, now, or at least during the next 30 days, please furnish us a complete - and itemized - list of all medical or other expenses which you have paid and for which a subrogation recovery interest is claimed. Show the amount paid and to whom it was paid and for what category of service or product it was paid.
   Note that If you wish a subrogation recovery, it will not be possible to make a claim for omitted or non-specific items. It will not be possible to recover payment for items you do not tell us about or do not give us sufficient requested details or for which you do not provide sworn testimony in court by doctors or others so that we can prove in court the reasonableness and necessity of the expenses.
3. Third,   give us the " name, " address, " phone number and " fax number of the person who has authority to (a) give us telephone updates of your subrogation interest, and (b) make any compromises in amount if negotiations with the defendant at trial time indicate compromises are necessary to preserve a recovery for you.
    
4. Also, please tell us --  if it becomes necessary to prove the subrogation amount in court, what arrangements do you have for your own employees and attorneys do the work and go to the expense, of obtaining both the necessary documents and also the necessary testimony. Defense attorneys are now requiring sworn trial testimony by the providers that the expense was necessary and that the amount was reasonable; they are arguing to the jury that the medical expenses are too high or were unnecessary treatment. Juries are now sometimes not awarding the full amount actually billed or paid for medical services, unless proof is provided in evidentiary form. It is necessary now, to safely assure a recovery, to have, at a minimum, depositions on written questions of the medical providers to present at trial.

   Alternatively, instead of you providing the work and expense yourself directly, to you wish us to do that for you?  If so give us a written statement that you wish us to do the work, and incur the expense and then bill you for the same.  Please tell us , in your response, that you will pay your share of the expenses and contingent attorney's fees to make the recovery of your subrogation interest. Your share of costs and attorney=s fees would be only that which is equal to the proportion that the amount of your separate gross recovery bears to the total gross recovery for your insured.)