Just Ask Susie . . . Continuing Education For Investigators    

       

(Disclaimer:  This is a fictitious report and generic format, created and written for educational purposes only. None of the names, locations or situations mentioned in this report are real).

(Note:  Always use professional Letterhead - no exception here). 

SMITH, WILLIAMS & ASSOCIATES

Private Investigators

  5555 Sunnyvale Street

Los Angeles, CA 33333

Telephone: (213) 555-1252

Fax: (213) 555-1111   e-mail: smithwilliams@aol.com

 

 

P.I. License # 2098  

Date:     (Always use the current date)

Client’s Name

Company Name

Address

Any town, CA 92654

 

  Re:

Claimant   

Claim No.

Date of Injury

Your File No.

Injuries - CT

Our File No.

:

:

:

:

:

:

John Doe

A2001-165 –SW

January 14, 2001

8457-AH

Neck, mid-thoracic & low back

2543569  

        

Dear Mr./Ms. Client:

We have completed the following (initial), (interim) or (additional) investigation on the above captioned case.   

ASSIGNMENT:

It was requested that we conduct two (2) days of videotape surveillance on Claimant, John Doe.  Mr. Doe has alleged injury to his neck, mid thoracic area and low back while lifting a pipe at D & L Construction

We were instructed to initiate surveillance activity at the Claimant’s residence during the early morning hours of Thursday, July 5, 2001. 

On Friday, July 6, 2001, you requested that we travel to Dr. Paul Wilson’s office, located at 555 Fifth Street, Los Angeles, CA, and set up a position of surveillance before the Claimant’s scheduled doctor's appointment at 8:00 a.m.  We were to obtain videotape evidence of the Claimant as he entered and exited the Sierra Medical Plaza in Los Angeles, CA.  In addition, we were to maintain surveillance after the Claimant’s appointment, in order to evaluate his present activities and determine if he is currently active or employed in a manner not consistent with his alleged disability.

A limited background check was to be completed on the Claimant, in order to verify his current residence address, telephone number and DMV information.  We were to make telephone contact with the human resource coordinator for D & L Construction at (213) 555-2233, ext. 4955 and speak with Donna Brown for past and present employment information regarding the Claimant.

Pursuant to your instructions, we have completed our limited background check on the Claimant, as well as two days of surveillance activity on John Doe. The results of our investigation to date are discussed below.

History and Length of Employment:

The claimant has been employed with D & L Construction Company since it first opened, 24 years ago, and is eligible for full retirement benefits in March 2002.  The claimant maintains an excellent work history and rarely misses a day of work.  He gets along well with his co-workers and supervisors.   No prior injury claims have been filed by the Claimant. 

Job Title:

Claimant Doe’s job title is Journeyman Mason; however, on the date of the subject accident, he was assisting his supervisor, Robert Smith with unloading pipes from a flatbed truck.

NATURE AND EXTENT OF INJURY:

John Doe has alleged on January 14, 2001, while working at D & L Construction Company, he was lifting a pipe weighing approximately 70 pounds when supervisor,  Bob Smith called out Doe’s name.  Mr. Doe turned around, rotating the upper part of his body only, while still holding the heavy pipe over his right shoulder. As he turned toward his supervisor, the heavy pipe swung in the same direction, injuring the lower half of his body that remained stationary.  Doe heard a loud popping sound in his low back area and felt a sharp, stinging sensation in the back of his neck, near where the pipe was resting.  Doe immediately dropped the pipe and just sat down on the pavement, unable to get up.  The claimant is alleging injury to his neck, mid thoracic and lumbar regions.  He has not returned to work as of the date of this report. 

Limited Background Check:

A check of our computerized property records revealed that John Doe currently resides at 777 Walker Street, Los Angeles, California 33333.  He has resided at this address for 20 years and is the owner of this property.  His current telephone number is (213) 555-1212.

Prior Address:

For eight years prior to moving to the Walker Street address, John Doe resided with his parents, Jane and Bob Doe at 4857 Community Avenue, Los Angeles, CA 33333. 

Department of Motor Vehicles:

A check with the Department of Motor Vehicles revealed that John M. Doe holds California driver’s license number N2397786. This is a Class C license with no restrictions, citations or moving violations.  His license is due to expire on his birthdate of February 5, 2003.  According to DMV records, Doe is the registered owner of a black, 1999 Buick, California license number V938472 and VIN W394839292V90.  Mr. Doe is a 180 pound male with black hair and brown eyes.  He is 48 years of age (DOB: 2-5-53). 

 

SURVEILLANCE

Thursday, July 5, 2001:

Weather:  Clear  

 

5:30 a.m.

(We) or (the investigator) departed our (name of City) office, en route to the Claimant’s residence at 777 Walker Street in Los Angeles, CA, 33333.      

5:45 a.m.

We arrived in the vicinity of the Claimant’s residence. The neighborhood is a middle income area.  Doe’s residence is a one story, tan, Spanish-style residence with a tile roof and an attached one-car garage. The residence sits at the end of a cul-de-sac in a nice area of  Los Angeles, CA. The Claimant’s yard was well maintained. The curtains were  open and lights were illuminated inside the residence at this early hour.  Surveillance was initiated in the vicinity of the Claimant’s residence.  

7:40 a.m.

Utilizing a suitable pretext, we placed a telephone call to the Claimant’s residence.  An adult female answered the telephone.  She advised us that Mr. Doe was home but was just leaving the residence to take their daughter to school.  

7:45 a.m. 

The garage door then opened and a Caucasian male entered the driver’s seat of a black four-door Buick, California license number V938472.  Moments later, a young female, approximately eight years of age, with medium length brown hair, alighted  the residence and walked into the garage.  She entered the passenger side of the Buick.  The child was carrying a blue backpack over her right shoulder and appeared to be wearing a school uniform.   

Doe was filmed backing out of the garage, turning his head from left to right as he looked over his shoulder, and in both side view  mirrors.  Doe turned his head in a normal manner, utilizing full range of motion, showing no signs of distress or discomfort.  Surveillance was maintained from a discreet distance. 

8:00 a.m.

The Claimant drove down various secluded side streets until he reached a McDonalds restaurant, located at 37999 Haverton Road, Los Angeles, CA. The claimant alighted the driver’s position normally.  He was filmed as he stood up straight, tucked his shirttail inside his pants in back and walked briskly towards McDonalds.  The claimant was not wearing any visible orthopedic device or support.     

The claimant was filmed as he dropped his keys on the ground and bent down from his waist to ground level in order to  pick up his keys.  His knees were slightly bent.  He did not appear in physical distress. The claimant raised the upper half of his body upward and continued walking into McDonalds, out of view.  The female child remained in the Buick.

8:10 a.m.

Claimant Doe was filmed as he exited McDonalds, carrying a drink in his left hand and a white sack in his right hand.  Reaching his car, he balanced the food, drink and his keys with his right hand, while opening the driver’s side door with his left hand.  The claimant was observed  bending over at the waist with his right knee on the driver’s seat.  He stretched over to the passenger side to hand the young female the contents of the white sack.  He then stood up straight and, with his right hand, tucked his shirt in again, before entering the driver’s position.  Four minutes and 32 seconds of film was obtained. The claimant departed McDonalds Restaurant and surveillance was maintained.  

8:25 a.m.

The Claimant arrived at St. Mary’s Catholic Elementary School,  located at 58900 Brown Street, Los Angeles, CA, where he dropped  the young girl off at school.  Moments later, the Claimant drove off.  Surveillance was maintained from a discreet distance as he drove south. 

8:30 a.m.

The Claimant arrived at  Brite Hand Wash & Wax on Bentley Street in Los Angeles, CA.  As he alighted his vehicle, fifty-three seconds of videotape evidence was obtained of the claimant as he spoke with one of the car wash attendants.

The Claimant was filmed as he stepped on to a 2’ curb leading with his right foot.  Walking at a brisk pace in a normal manner, the Claimant opened the door to the car wash walked inside, out of view.  He showed no signs of distress, discomfort or physical impairment. Surveillance was maintained.    

9:30 a.m.

The Claimant’s black Buick was hand polished and the attendant leaned on the horn, signaling  his car was ready.  Doe exited the waiting area and, once outside, stopped to light a cigarette.  He tucked his shirttail into his pants and was filmed as he turned his head from left to right, before stepping off the 2’ curb.  He  was filmed laughing with the attendant, as well as  bending over at the waist, while walking around his vehicle, inspecting it.  The Claimant squatted down and bent his neck under the frame of his Buick, pointing something out to the attendant.  The attendant also squatted down to look under the body frame.    

A loud noise of a truck passed nearby.  This apparently startled the claimant,  causing him to look in the direction of the noise.  He was filmed as he  turned his head sharply to the left.  As he turned his neck quickly, his body remained positioned and stationary. The Claimant then turned his neck quickly to the right and held it there, exhibiting full range of motion bilaterally.  Film was obtained.

10:05 a.m.

The Claimant got into his vehicle and drove westbound on Bentley Street in Los Angeles, CA.  Surveillance was maintained. 

12:40 p.m.

No activity.   Surveillance was maintained.  

2:35 p.m.

The garage door was electronically opened and the Claimant was filmed getting into the driver’s side of his black Buick. Once inside the vehicle, he began adjusting his seatbelt.  The Claimant backed out of his driveway, looking over his right shoulder, utilizing full range of motion.  Surveillance was maintained.

The claimant drove the same side streets as before.  Arriving at St. Mary’s Elementary School, he parked his vehicle on the southwest curb and lit a cigarette while sitting in his vehicle.

2:45 p.m.

A short time later, the young girl we observed earlier in the morning, exited the school grounds and walked toward the black Buick.  After the young girl got into the passenger side of the vehicle, film was obtained of the Claimant bending over to the passenger side,  assisting the child with her seatbelt.  The claimant then drove away and surveillance was maintained from a discreet distance.    

3:15 p.m.

Doe and his passenger arrived at his residence and the garage door opened electronically. Once again, the garage door closed before the claimant exited his vehicle.  Surveillance was maintained.  

5:20 p.m. 

Due to a lack of activity and as a cost-saving measure, we telephoned your office and advised you of our status.   We were instructed to discontinue surveillance on this date, as it appeared the claimant would remain inside his residence for the remainder of the day.  

6:00 p.m.

We arrived back at our Los Angeles office.  

 

FRIDAY, JULY 6,  2001:

Weather:  Clear 

 

DR. PAUL WILSON, SIERRA MEDICAL PLAZA, 555 FIFTH STREET,

SUITE 502, L.A. CA  33333:

 

7:15 a.m.

(We) or (Our investigator) arrived at the address captioned above. After setting up a position of surveillance, we walked into the main entrance of the  medical building and located the building directory. Dr. Paul Wilson was listed in Suite 502, along with his specialty, Orthopedic Surgery .   We walked back to our vehicle and continued waiting for Claimant Doe to arrive for his scheduled appointment at 8:00 a.m.  

No activity noted. Fifty-two seconds of videotape film was obtained of this white, five-story professional building and surrounding area at the Sierra Medical Plaza.  Surveillance was maintained. 

8:00 a.m.

The Claimant arrived at Sierra Medical Plaza, driving into the parking lot at a fast speed.  He abruptly pulled into a handicapped spot near the main entrance.  As he alighted his vehicle, he appeared to be in somewhat of a hurry.  Film was obtained as the Claimant tripped over a parking barrier, landing on his hands and knees. He remained in this position for approximately four seconds and then stood up. The Claimant appeared agitated at having tripped.  

He then bent at the waist and dusted his pants off with both hands.  He continued walking towards the main entrance of Sierra Medical Plaza at a somewhat slower pace.  The claimant appeared in no apparent discomfort after his fall.

9:50 a.m.

The claimant departed Sierra Medical Plaza, walking briskly to his car.  Doe got into the driver’s position of his Buick, lit a cigarette, put his seatbelt on and departed the area.  Surveillance was maintained.  

10:05 a.m.

We telephoned your office from our remote location, at which time you requested that we discontinue surveillance  on Claimant Doe.   A total of (time goes here) videotape was taken of the Claimant’s activities on this date.

10:40 a.m.

We arrived back at our Los Angeles office.  

COMMENTS:  

Suggestion # 1: 

We believe this completes our investigation to date and are placing our file in abeyance, pending notification from your office.  

Suggestion # 2:  

We believe this completes our investigation to date and are closing our file accordingly.  Should you have any questions, comments or additional investigation, please do not hesitate to contact our office.  

Suggestion # 3:  

We are continuing with efforts  in this matter and will keep your office apprised of our findings in the near future.  

Suggestion # 4: 

‘Summarize’ your investigation report under this heading.

(Note:  It is always appropriate and proper to thank your clients for choosing your company.  Never take your clients or their assignments for granted.) 

It is a pleasure to be of service to you and we look forward to being of continued service in the near future.  

Sincerely,

SMITH, WILLIAMS & ASSOCIATES

 

James A. Williams 

JAW:sw  

Enclosures: Videotape evidence, invoice