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In almost twenty years in the practice of law and at least half as many representing people injured due to the fault of others at hotels, resorts, spas and other venues throughout the United States, the Caribbean and Mexico, just to name a few, if I had to compile my wish list of information I would like to have from every prospective client, it would be:

Photos & Video

For injuries involving a premises defect, if possible, take photos or video. Better yet, have a family member or traveling companion do it for you. Be careful. Don't concentrate solely on the defect, be it the cracked staircase, a broken threshold or dangerously slippery tile, to the exclusion of everything else. Remember to provide some context by photographing the general area surrounding the defect. Let me see the approach. Check your photos carefully. Are they in focus? Is the defect clear in the photos? Don't worry if it's not too clear - after all, if it was open and obvious you wouldn't have fallen on or over it. Are you able to place a quarter or a dollar bill (really any object with a known size) next to the defect to provide some sort of scale so I can determine size?


Save all names, email addresses and cell phone numbers of any eyewitnesses, especially non-employee hotel and resort guests who eye witnessed the accident. It is difficult, if not impossible, to determine the identity of "that firefighter from New Jersey" or "the orthopedic surgeon from Denver" who told you he saw the whole thing when dealing with a 500-room Caribbean resort. It is helpful if you have an email exchange with the witness either prior to leaving the resort, or just upon your return. Keep it very simple, thank them for assisting you and being willing to speak the truth about what they saw.

Check-In Docs

Save all hotel check-in documents - they may contain forum selection or choice of law clauses. These are almost always hidden in the check-in materials that you are forced to sign in order to stay at the hotel. We like to know about these sooner rather than later, if at all possible.

Booking Information

Print-off and save all your booking information. This could be email confirmations, email discussions with concierge, getting reservations in advance of your stay; essentially anything relating to the trip before it was undertaken. This is important as it may help us in any fight contesting jurisdiction, or forum non conveniens (inconvenient forum).

A Written Summary

Provide me with a summary of the events as they happened. Describe in as much detail as possible the exact location of your injury at the hotel, spa or resort property. Save all resort maps, guides and brochures. I will tell you that a significant percentage of the prospective clients that I see are often more enraged with the hotel or resort's treatment of them following the injury than they are with the injury itself. That is absolutely understandable. However, while I am more than happy to listen about the unsanitary conditions of the local hospital, my focus as your lawyer will be on the manner in which you were injured. How did it happen? Why did it happen? What is the mechanism of injury? Is this a design defect? Was the glass properly set? Was the water slide drop or plunge pool deep enough? How was the water pressure maintained? Why wasn't there a waterslide attendant at the top of the water slide when your child went down? Did they use the safety glass for the application? How well was the tile maintained? Was hotel security contacted? Did security follow-up when you reported a strange individual on the hotel premises? These are just some of the questions that roll through an attorney's head when discussing a possible new case with a client. A written summary containing all facts pertinent to your injury helps me understand if the hotel, resort, spa or other venue has responsibility for your injury and assists you with retention of pertinent facts prior to our meeting.

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