Medical records tend to be voluminous and intimidating. It seems impossible to get them on time and complete on the first try, and when they do arrive, you can't read the hand-written notes or make sense of the typed ones. I may not be able solve those problems for you, but I do want to share several best practices for getting the records you need and managing them throughout the case.

1. Start Early. Preparing records for trial starts well before trial. Start identifying medical providers as soon as the plaintiff has identified them. This is as early as their intake meeting if you are the plaintiff. For the defense, look at their pre-suit claim or demand. Review their responses to first interrogatories and requests as soon as they arrive.

2. Call Providers. It is frustrating to learn a month or more later that your request for records was mailed to the wrong location or the record custodian is actually at a different location. You can save yourself time and hassle by calling the providers ahead of time to make sure you have the correct address and direct the Request to the correct person.

3. Get and Stay Organized. Medical records are voluminous. Don't wait until you have hundreds of pages before you organize them.

4. Categorize Them. You may just need the nursing records, or records of a certain treated. Perhaps you need everything (or have no idea what you will need) and better sort them chronologically. Think about how you and your attorney will use the records and categorize them to suit that purpose.

5. Get Certified. At the time you collect records, make sure they are certified so you aren't scrambling during trial preparation to get a full and certified set for evidence.