PRIVILEGED & CONFIDENTIAL

ATTORNEY-CLIENT WORK PRODUCT

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Lead Paint Case Evaluation

Case Caption: Date Prepared:

I.Background/Summary

A. Insured:

B. Plaintiffs First and Last Name (include gender):

C. Plaintiff’s Current Age and DOB:

D. Plaintiff’s SSN and HICN if applicable:

E. Address of Insured’s Subject Property (“Property”):

F. Years of Occupancy at the Property:

G. Highest Overall BLL & Date:

a. Highest BLL while at the Property & Date (indicate if venous or capillary):

b. Lead Paint Violations at the Property? Y/N:

c. If Yes, date of violation and locations at the Property that lead was detected

d. What actions did insured take in response to issuance of violation?

H. Defense Firm & Lead/Trial Attorney:

I. Plaintiffs’ Counsel and Lead/Trial Attorney:

J. Jurisdiction:

K. Judge/Mediator:

L. Trial Date:

  1. Mediation Date:
  2. Settlement Conference Date:

M. Demand:

N. Authority Requested:

O. Negotiation History:

  1. Medical History (in-utero through present): include a timeline of BLL
  1. Plaintiff’s Educational & Social History:i.e. IQ levels, school records & criminal history
  1. Plaintiff’s Employment History:
  1. Plaintiff’s Family History:
  1. Other Significant History:
  1. Residence History:

A. Residential History/Exposure (as to all defendants):

B. Residential History/Exposure (as to insured):

C.Alternate Sources of Exposure (non-defendants)

  1. Identification of Experts & Testimony/Reports:
  1. Defense Expert(s) Findings:
  1. Plaintiff’s Expert(s) Findings:
  1. Damages:

A. Economic Damages:

1. Medicals (provide range and explain): If the jurisdiction limits or requires reduction of any medical recovery to amounts actually paid by health care providers, please explain. If the actual amounts billed and accepted as payment are unknown, please include an estimate based on the best available information.

2. Lost Wages (provide range and explain): Provide plaintiff’s estimate, our economist’s estimate and the amount the jury will likely accept. If we have not retained an economist, provide an estimate of the amount that plaintiff can likely substantiate.

B. Non-Economic Damages:

1. Pain and Suffering (provide range and explain):

C. Exemplary/Punitive Damages:

  1. Apportionment/Setoffs:

A. Jurisdictional Rules Regarding Apportionment/Setoffs:

B. Estimated Number of Shares/Defendants on Jury Form:

C. Share Likely Assigned to Insured:

D. Total Estimated Setoffs:

  1. Exposure:
  1. Estimated High, Medium, and Low Verdict Range (provide amount as to all defendants and give supporting information based on recent verdicts): Verdict history should explain whether verdicts were upheld or struck down on appeal.
  2. Percent Chance of a Defense Verdict on Product Identification/Exposure (provide a numeric percentage and explain basis for estimate):
  3. Percent Chance of a Defense Verdict on Medicals (provide a numeric percentage and explain basis for estimate):
  1. Updated Defense Budget:
  1. Estimated costs up to date of trial:
  2. Cost for trial:
  1. Other Pertinent Details to Assist in Our Evaluation:
  1. Recommended Strategy/Next Steps for Disposition of the Case:

(Including, but not limited to, pending motions)

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