Subpoena educational records. Educational records sometimes reveal past injuries from sports and prior medical conditions. For a plaintiff claiming brain trauma or brain injury, educational records can reflect that he or she has memory deficit, a prior history of testing at below average levels, or even a learning disability. Subpoena employment records. Employment records reveal significant information such as salary, past salary, medical history, job performance prior to the accident, promotions, raises, and workers' compensation claims.
Many employees are subject to physical examination prior to beginning employment.
Such records can reflect past illnesses or surgeries. If the plaintiff is working doing physical labor, he or she might be subject to yearly physical examinations that can reveal hearing, visual, or other physical deficits. Clearly list each record you wish to receive when issuing a subpoena for employment records. The subpoena should stress that the records include items such as the plaintiff's job applications, references, doctor or physician notes or excuses, and time sheets. Subpoena medical records.