For Our Clients

For Our Clients

We know this is a difficult time for you, and recalling details of your incident can be painful. However it is one of the most crucial components in understanding and obtaining the most imperative details. We kindly ask that you fill out our Confidential Client Information Questionnaire.
We thank you in advance for your help in aiding us with this process.

3. Form Interrogatories

If your case enters into litigation you may be requested to fill out an Interrogatories Form. Should this be the case here is some information and questions that may be asked. Form Interrogatories.

To Our Prospective Clients:

Gain the Confidence to Move Forward.

Del Hovden has handled cases across the legal spectrum for over 35 years. Over that time he developed a simple list of things every person involved in a mishap should consider. These have no bearing on whether you consider Del or not for your legal issues, but they do constitute excellent habits to have at the ready whenever you find yourself in difficulties.

Having handled cases for more than 35 years there are a few things which I suggest you consider, whether you hire my firm or not. Insurance companies do not pay money willingly, even your own carrier. They do so only because they have little other choice, which makes sense. In order to effectively represent you, any attorney your choose needs information to effectively represent you and your claim. If you are in any kind of situation, follow these instructions carefully as possible:

1. Write down everything that happened while it is fresh in mind. You might forget details. Names and ID of witnesses, names of police officers, statements of those with details of the accident. Even if you think, or other say you have a “slam dunk”case, take the time to get the details. Know that those on the other side will make arguments against you. They seldom concede even obvious events. Write it all down.

2. Keep track of money you spend for co-pays, medical care costs, medications and the like. These expenses add up. Track even the smallest expense.

3. Keep track of your injuries and their effect on your life. Keep a daily diary. Experience tells us that many people forget pertinent details and what they went through to recover from serious injuries.

4. Photograph anything of significance. Yes, a picture speaks more than a thousand words.

5. Share with your counsel your pertinent medical history. We can best help you when we know any prior injuries or claims. The defense spends millions to find everything when faced with a serious claim. They use that against you. Be sure your counsel is armed with all the information necessary to best protect you.

Above all, do not simply let the insurance company, yours or theirs, pressure you into a quick, low ball settlement. You have the right to be treated well and get your life back on track. Call us for a free consultation to see what your options truly may be.


There are many different types of settlement conferences which can occur during the life of a case. The type of conference for any individual case will depend on the specific claim and breadth of issues of the case.

In order to consider entertaining the idea of a settlement conference, the issues in damages of that client or group of clients must be fairly well known to entertain the idea of settlement. If we understand how a specific accident or incident happened, and if it is fairly well-known by both sides how the accident or incident happened we must also evaluate whether causation is well defined and if the damages are well-known.

If all of these topics are well identified before a lawsuit is filed it is not uncommon that the opposition would want to proceed to a settlement conference even before a lawsuit is filed.

Pre-litigation settlement conference

Pre-litigation settlement conference can, in a select few cases resolve the case before a lawsuit is filed when all of the necessary elements to the claim are well known before it is necessary or appropriate for the plaintiff to consider filing a lawsuit. In addition, even wear each element cannot be specifically identified in advance of litigation, some thoughtful claims examiners and ensures opt for the opportunity to try and settle the case even when there is some uncertainty in one or more areas of a case. The reasons to do so or obvious. There is a cost savings which is afforded to both sides in such a situation. While true that damages may be uncertain, it is likely in many cases that damages in the cost for caring for an injury can be pretty well known even when the patient is in the midst of care. In these instances, although rare, it can’t be advantageous to both size to consider such a settlement conference.

Enterprising parties look at these conferences as an opportunity to help the client put the case behind them and get on with their life even one while they are still in treatment if there is some reasonable assurance that they will complete treatment in the near future, or with limited exposure for long-term problems.

Litigation settlement conferences

Litigation settlement conferences are the most typical type of settlement conference. These occur once all of the parties are engaged in the case and have had an opportunity to examine the issues of liability, causation, and damages, to the point they are comfortable with discussing all aspects of the case with a mediator.

The selection of a mediator is a key component of litigation settlement conferences. All parties must have confidence that the selected mediator has the depth of experience and knowledge to bear on the case. The mediator must be in a position to evaluate, and have experience with, the particular issues the parties will face in trial. All parties must view the mediator as being one who is fair to all sides and who can knowledgeably predict, based on his or her experience, the true value of the case. He or she must be knowledgeable on what typical range of value the parties might expect in trial for the given facts. The mediator must be able to gauge the likelihood of plaintiffs success on liability and the likely range of value a jury would assess for the nature and extent of the injuries that the injured plaintiff has suffered. Moreover counsel for the parties must have confidence in the mediators ability to make this assessment and make a fair determination on case value.

In most cases, the mediator will meet separately with each side and determine, confidentially, the facts that will be presented to the jury. The mediator must probe the parties and their counsel to determine the accuracy of the material provided to the mediator by each side. What is the deposition testimony bearing on the issues? What documentary evidence supports or contradicts witness testimony? All of this bears on the credibility of the parties and their counsel.

The work of the attorney is to prepare the case so as to maximize their opportunity of success, whether it is at mediation or a trial.


It is not unusual that there are many months to a year or more for a case to reach trial, from the time that it is filed.

In advance of trial there will be extensive discovery in most cases. Discovery includes written questions called interrogatories, request for admissions, request for production of documents and deposition.

It is also quite common in advance of trial that the parties will make a concerted effort to resolve the case through a settlement conference or, potentially, arbitration of all or some part of the case to shorten the trial experience.

Trials in personal injury cases can last weeks or months depending on the issues for the judge or jury to resolve.

Of the cases tried to a jury, in California, the jury will typically consists of 12 persons selected from the community. The jury selection process is called voir dire. During this part of the trial the attorneys will ask prospective jurors questions concerning their background and life experience that could bear on the issues that the attorneys expect will be presented during the trial process.

During trial, the case will start with presentation of evidence by the plaintiff. This is called The plaintiff’s case in chief. Once the plaintiff has rested, the defendant or defendants have the opportunity to present their case in chief.

This part of the trial is then followed by plaintiffs rebuttal evidence and the rebuttal evidence by the defense.

Once all parties have rested, the jury will hear plaintiffs opening argument, the defense arguments and plaintiff’s rebuttal argument. The case is then submitted to the jury which deliberates and determines a fair and just verdict.

Clients in personal injury cases must expect that they will be present for each day of the trial and during jury deliberation. It is important that the jury see the plaintiff in court and waiting for the jury verdict and be present for all of it.

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