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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 petition which we have served on the client=s behalf.

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 three items.

< First, immediately tell us the total amount for which you seek recovery and give us a brief summary of the type of expenses (e.g., medical, wage replacement, et cetera).

< 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. (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.)

[Alternatively, tell us that instead you wish us to do the work, and incur the expense, to include your subrogation interest amounts and prove these subrogation amounts at trial.. 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.)]

< Third, give us the " name, " address, " phone number and " fax number of the person who has authority to (a) give us telephone updates if needed 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.