Whitney A. Healy
Habush Habush & Rottier S.C.
Appleton

Catherine A. La Fleur
La Fleur Law Office S.C.
Milwaukee

Heather L. Nelson
Everson, Whitney, Everson & Brehm S.C.
Green Bay

Jacob R. Reis
Habush Habush & Rottier S.C.
Appleton

Eric J. Ryberg
Habush Habush & Rottier S.C.
Madison

Kristen S. Scheuerman
Weiss Law Office S.C.
Appleton

8:30 a.m. Screening, Accepting and Signing Up Personal Injury Cases

• Initial client contact – screening, client interviews, CCAP and other research
• Eventual value vs. true potential for recovery
• Placing proper emphasis on damages vs. liability
• Keeping costs and time in proper proportion to value and risk
• Eventual fees vs. risk of loss
• Public duty and pro bono representation

Whitney A. Healy

9:00 a.m. Defense of Personal Injury Cases From Retention Through Trial

• Initial case information
• Who are my clients?
• Initial analysis and strategy
• Defendant’s perspective: jury or non-jury considerations
• Client communications
• Witness preparation for discovery: the defendant, fact witnesses, experts
• Defense expert witnesses: damages and liability
• Trial: theme of the case, liability, damages
• Demonstrative evidence – what to use and how to offer it
• Motions in Limine, Jury Instructions, Special Verdicts
• Closing arguments

Heather L. Nelson

9:30 a.m. Pre-Suit Investigation

• Witness statements, record collection, physical evidence
• Finding coverage
• Will you need experts?
• Where to find them
• What if your expert doesn’t agree?
• Evaluation of the case: strengths, weaknesses, viability
• Case theme
• Do you need further investigation?
• Presenting a demand letter
• If and when a suit would be advisable
• The value of the case: how to find this information
• In a perfect world: what should be in the client’s file? (And what shouldn’t?)

Kristen Scheuerman

10:00 a.m. Statutes of Limitation, Notices of Claim/Injury, and Other Traps for the Unwary

• Requirements for government claims
• Traps to avoid in filing notices and claims

Eric J. Ryberg

10:30 a.m. Break

10:45 a.m. Discovery – Formal and Informal

• General Considerations
• Authorizations
• Interrogatories
• Depositions
• Preparing for your first deposition
• Dealing with the difficult witness
• Should you try to win the case? Or set it up for trial?
• Requests for Admission

Kristen Scheuerman

11:15 a.m. Subrogation/Section 102.29/ERISA/Medicare Set-Asides

• Collateral source rule
• Made whole rule
• Health insurance liens

Kristen S. Scheuerman

12:00 p.m. Alternative Dispute Resolution

• Wis. Stat. sec. 802.12(2)(a)
• Mediation Best Practices
• Attorney's role
• • Preparing the client
  • Preparing submission
  • Heads up to mediator
• Mediator’s role
• • Can depend on mediator and parties
  •  Communication
  • Confidentiality
  • Preparation of Mediation Agreement
  • Payment

Heather L. Nelson

12:15 p.m. Lunch

1:15 p.m. Preparing for Trial

• Pre-trial motions including motions in
• Scouting the courtroom for technology
• Jury instructions and verdict
• Preparing a trial notebook
• Jury selection
• Opening statement
• Presentation of evidence
• Direct examination of witnesses
• Cross examination of witnesses
• Proving specials
• Proving pain, suffering and disability
• Closing arguments
• Post-trial relief

Catherine A. La Fleur

2:15 p.m. Break

2:30 p.m. Behind the Curtain: What they don’t tell you about practicing PI in law school

• Reading medical records
• Saving money on medical records – use of the HITECH Act
• Pretrial stipulations
• Scheduling conferences
• The importance of understanding the local rule
• Jury instruction and verdict conference
• Getting along with the other side

Jacob R. Reis

3:30 p.m. Program Concludes

• Receive step-by-step guidance through every stage of a personal injury case
• Understand challenges and strategies from both plaintiff and defense perspectives
• Discover best practices for client selection, pre-suit investigation, mediation, and trial preparation
• Avoid traps for the unwary in filing notices and claims
• Acquire sample documents, practice tips, and tools to simplify your workflow and keep you organized

• Attorneys seeking to add personal injury to their practice
• Experienced personal injury lawyers seeking a refresher
• General practitioners
• Paralegals

YLD Discount!

Young Lawyers Division members receive a $20 discount on tuition.* Discount applied automatically upon log-in.

*Young Lawyers Division Members are State Bar member attorneys 36 years of age or younger, or within five years of admission to the State Bar of Wisconsin. If you’ve opted out of YLD, you will not receive this discount. The $20 discount only applies to in-person, live webcast, and webcast replay versions of this seminar – not CLE OnDemand. YLD members with Ultimate Passes, other CLE passes, or PINNACLE discounts are not eligible for this discount.

Book Bonus!

Wisconsin Civil Procedure Before Trial
Save 15% on Wisconsin Civil Procedure Before Trial.* It’s your roadmap to the pretrial civil litigation process in Wisconsin courts, from accepting a client to pretrial motions. Use discount code CA3773 when you order online or by calling (800) 728-7788.

*Discount applies to both print and digital Books UnBound editions of this title and cannot be applied to previous purchases. Offer valid through 12/31/26. For Books UnBound users, discount may be applied to purchase of individual Books UnBound title only and may not be used on the purchase of libraries. Discount cannot be combined with any other offers.

The Build Your Practice Series from State Bar of Wisconsin PINNACLE^® introduces you to the fundamentals of various practice areas. Gain the tools and information you need to develop a new area of practice and expand your firm's offerings. Build Your Practice Series programs are endorsed by the State Bar's Young Lawyers Division.