Q. How do I know what information to provide to my economic damages expert?

A. At Tinari Economics Group we request each attorney submit a completed Fact-Finding Questionnaire (FFQ) on behalf of their client. Our FFQ's (available at www.TinariEconomics.com) are tailored to the different types of tort litigation i.e., Personal Injury, Wrongful Death, Wrongful Discharge. The questionnaire requests basic information such as the claimant's date of birth, level of education, and marital status. In addition, important information regarding specific fringe benefits received by the claimant (as an employee), and the types of services provided to surviving family members (in a Wrongful Death action) is also requested. In conjunction with FFQ, we recommend that copies of income tax returns, W-2 Wage and Tax Statements, Complaint, deposition transcripts and Answers to Interrogatories be included with the initial case documents. We discourage attorneys from sending detailed medical records. Such records are cumbersome and add little value to establishing the underlying damages claim. Often, after reviewing the file documents we determine that 1) additional documents may be necessary and/or 2) that we have further questions. These issues are generally communicated in a letter to the attorney. However, some attorneys prefer that we deal directly with their client to obtain the remaining information. From our perspective, this level of interaction expedites the fact-finding process. 

All sources of information relied upon in calculating damages is fully referenced in our appraisal report. Occasionally, attorneys will request that the responses to our Fact-Finding Questionnaire not be cited as a source of information. In our opinion, concerns over the disclosure of this information to an adversary is unfounded.

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