Tip No. 12 There is a saying that the devil is in the detail. . .

... the importance of the detail is sometimes what is not in the records. 

 A medical records summary should not include only the records post-accident that refer to the accident related-injuries. The attorney needs to know what is not in the records: i.e. whether the plaintiff is a hypochondriac or a stoic – did he go to the ER for every sniffle or bruise or did he never go to the doctor. You want to know not only what the accident-related injuries and treatment were, but whether the plaintiff had a pre-existing medical condition, whether or not it contributed to the claimed injuries.

The corollary to the above rule, is the rule that one should not have to go back to the actual records to see what was omitted  – except perhaps to confirm that the handwriting is illegible and the words undecipherable. The reviewer will of course exercise a degree of discretion in determining what should be included in the summary, but it is more than a little embarrassing to have your expert (who reviewed the records) mention a report that whoever prepared the summary deemed not important and neglected to include.