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Welcome!

Note: Your privacy is very important to us. To better serve you, the form information you enter is recorded in real time.

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Thank you for your interest in us representing you in this case. Our experienced legal team handles some of the largest cases nationally for catastrophic injury and death, product liability, commercial litigation, and mass torts. 


Our attorneys have diverse and varied backgrounds, having previously worked for the best and largest defense firms, companies, prosecutors’ offices, and other plaintiffs’ firms. Collectively, our attorneys have represented hundreds of thousands of people. 


Our team is also made up of some non-lawyers like public advocate Erin Brockovich who has spent her life fighting for families just like yours. 


There are a few steps to this process. The first step is to answer the following questions to help us see whether we are able to represent you in this case. If you qualify, you will be able to sign all necessary documents on your computer or your phone so our lawyers and client management team can begin their work on your behalf. 


If at any point you prefer to talk to someone on the phone and go through this with them, you can call (877) 285-7933. Let's get started.

Before We Proceed

Before we proceed, are you represented by another lawyer in connection with this case?*

Please confirm that you received an email or letter terminating that representation. Our team will need a copy of that email/letter sent to us. That contact information will be provided at the end of the form, so please make sure you have a pen and paper handy.

Thank you for that information, we are not legally allowed to speak with you at this time. In the future, if you decide to formally terminate your prior representation, and can provide us with a copy of the termination email/letter, we can then move forward.

Thank you for that information, we are not legally allowed to speak with you, if you currently have other representation. If you determine that you do not have representation, we can then proceed forward.

Pre-Qualification

Name*
Do you have multiple children diagnosed with autism or an intellectual disability, and/or have early intervention services for autism or have an IEP for autism for multiple children?*

Please note: if you have multiple children diagnosed with autism or an intellectual disability, and/or have early intervention services for autism or have an IEP for autism, please fill out this form once per child.

Pre-Qualification

Were you ever prescribed or given a sample of Topamax by a doctor (physician) while pregnant?*

Pre-Qualification

Did you use one or more SSRI drugs (antidepressants) while pregnant? *
Examples include, but are not limited to: Celexa, Lexapro, Prozac, and Zoloft.
While pregnant, did you use alcohol after you knew you were pregnant?*
Did you use one or more illegal drugs while pregnant?*
While pregnant, did you use tobacco after you knew you were pregnant?*
Were you or the affected child’s father diagnosed with autism or an intellectual disability?*
Pre-Qualified

Pre-Qualification Update

Thank you for providing that information. Based on your answers, we have come to the unfortunate conclusion that we will not be able to represent you in this case. Please do not infer from our decision that you do not have a meritorious claim or could not prevail on your claim. We make no representations in this regard. Another attorney may disagree with our criteria and accept your case. We encourage you to seek legal advice from another attorney if you desire a second opinion as to whether you should pursue a claim. We regret that we are unable to proceed with your potential case.

Qualification

Which of the following applies to ? Check all that apply:*

Did you suffer from gestational diabetes, gestational hypertension, or require hospitalization due to an infection with fever?*

Was born before the 26th week of pregnancy?*

Is diagnosed with Down syndrome, Fragile X syndrome, Tourette syndrome, and/or tuberous sclerosis?*

Qualification

Were you over 40 years of age when was born?*

Was the father over 45 years of age when was born?*

Did you take acetaminophen, or were prescribed Topamax during pregnancy, in Michigan?*

How old was when they were diagnosed with autism and/or intellectual disability?*

Please enter an age between 0-18.

Qualification

What is the name of the school was going to when they received the IEP or early intervention services?*

What is the address of the school was going to when they received the IEP or early intervention services?*

When was born?*

Is younger than the age of 18 as of today?*

Today's Date - For Calc
Please confirm today's date
Stage 2 Qual In-progress

Qualification Update

Thank you for providing that information. Based on your answers, we have come to the unfortunate conclusion that we will not be able to represent you in this case. Please do not infer from our decision that you do not have a meritorious claim or could not prevail on your claim. We make no representations in this regard. Another attorney may disagree with our criteria and accept your case. We encourage you to seek legal advice from another attorney if you desire a second opinion as to whether you should pursue a claim. We regret that we are unable to proceed with your potential case.

Topamax Qualification

Approximately what date were you prescribed/did you take Topamax?*

Were you prescribed or given samples of Topamax by your doctor during your pregnancy with ?*

z Topamax Qualification Checkbox

Qualification Update

Based on the information you provided, our team of lawyers is able to represent you! The next step in this process is to sign all necessary documents, which I will help you through. Once that is complete, you will have established an attorney-client relationship with us, which allows us to begin working on your case. These documents include the following: 

  1. Engagement Agreement which outlines the terms of the contract between us and that allows us to represent you.
  2. Power of Attorney document that allows us to work on your behalf under certain circumstances.
  3. Medical Authorization form that allows us to get medical records on your behalf.
  4. Declaration form that you sign ensuring that all information you provided is accurate.
  5. FERPA form, which allows us to get school records on your child’s behalf.

If you would like someone to help you through this process, you can call (877) 285-7933. If you call, please know that they will need to go through the questions with you again to ensure all information is accurate.

Thank you for providing that information. Based on your answers, we have come to the unfortunate conclusion that we will not be able to represent you in this case. Please do not infer from our decision that you do not have a meritorious claim or could not prevail on your claim. We make no representations in this regard. Another attorney may disagree with our criteria and accept your case. We encourage you to seek legal advice from another attorney if you desire a second opinion as to whether you should pursue a claim. We regret that we are unable to proceed with your potential case.

Acetaminophen Qualification

For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.

While pregnant, did you consume at least 10 doses of acetaminophen with ?*

A “dose” means the number of tablets or volume of liquid recommended on the product packaging for an adult.
Did you consult your MD or MD’s nurse for approval to use acetaminophen while pregnant?*
Did your MD & MD’s nurse approve using acetaminophen while pregnant?*
q QUALIFIED FOR ACETAMINOPHEN CHECKBOX

Qualification Update

Based on the information you provided, our team of lawyers is able to represent you! The next step in this process is to sign all necessary documents, which I will help you through. Once that is complete, you will have established an attorney-client relationship with us, which allows us to begin working on your case. These documents include the following: 


  1. Engagement Agreement which outlines the terms of the contract between us and that allows us to represent you.
  2. Power of Attorney document that allows us to work on your behalf under certain circumstances.
  3. Medical Authorization form that allows us to get medical records on your behalf.
  4. Declaration form that you sign ensuring that all information you provided is accurate.
  5. FERPA form, which allows us to get school records on your child’s behalf.”


If you would like someone to help you through this process, you can call (877) 285-7933. If you call, please know that they will need to go through the questions with you again to ensure all information is accurate.

Thank you for providing that information. Based on your answers, we have come to the unfortunate conclusion that we will not be able to represent you in this case. Please do not infer from our decision that you do not have a meritorious claim or could not prevail on your claim. We make no representations in this regard. Another attorney may disagree with our criteria and accept your case. We encourage you to seek legal advice from another attorney if you desire a second opinion as to whether you should pursue a claim. We regret that we are unable to proceed with your potential case.

Attorney Employment Agreement

CONTRACT OF EMPLOYMENT AND CONSENT TO FEE SHARING (TOPAMAX® LITIGATION)

By this Agreement (this “Agreement”), employs the Watts Guerra LLC, Watts Guerra LLP, Sunridge Law Group, LLC, the Law Office of Douglas Boxer called “the Firms,” on behalf of Client and Client’s minor child (collectively, “Client”) to serve as Client’s attorneys for the sole purpose of prosecuting Client’s claims against those responsible for the manufacture and distribution of the Topamax® taken by Client during her pregnancy with Client’s minor child, which Topamax® caused Client’s minor child to suffer autism spectrum disorder (collectively, Client’s “Claims”).

1. THE FIRMS’ AUTHORITY. Client fully authorizes and directs the Firms to manage and handle my claims as they deem proper and to investigate and prosecute them, with or without filing a lawsuit, in any manner they deem advisable. Client authorizes the Firms to deliver in my name any and all notices, receipts, authorizations, releases, pleadings and any other documents proper in and to the handling of my claims. Client authorizes the Firms to use their professional judgment and any relevant documents, records, or other information that the Firms deem necessary to proper representation of Client. If, at any time, the Firms determine, for any permissible reason, that prosecution of Client’s claims should be discontinued, the Firms may withdraw from my representation. Client understands and agrees that the Firms may transmit Client’s protected health information electronically in the course of representing Client. The Firms do not provide tax advice.
2. CLIENT’S COOPERATION. Client agrees to cooperate fully with the Firms, disclose all relevant facts and promptly advise the Firms of any change in address or telephone number, and to promptly comply with all reasonable requests of the Firms on all matters related to this contract. Client consents to being contacted by the Firms via telephone, text message, email, and specifically through the use of robocall technology as well as any other necessary methods of communication. Client understands that failure to fully cooperate may be a basis for termination of this contract. Client agrees not to attempt on his/her part to unilaterally settle the claims made the subject of this contract. The Client will rely exclusively upon the representation of the Firms during any settlement negotiatNioon sse. ttlement will be made without the Client's consent.
3. CONTINGENT FEE ARRANGEMENT. The Firms will assume joint responsibility for Client’s representation. In consideration of such legal services, Client hereby assigns and grants to the Firms the following percentage of any monies, interest, settlement, judgment, Court awarded costs or attorney fees or property recovered: FORTY PERCENT (40%). Client consents to the Firms’ sharing these attorneys’ fees 2.25% to the Law Office of Douglas Boxer, 47.5% to Watts Guerra LLC, 2.5% to Watts Guerra LLP, 47.75% to Sunridge Law Group, LLC. Client consents to the Firms sharing their attorneys’ fees with local counsel as necessary. Attorneys’ fees will be determined before repayment of expenses; that is, attorneys’ fees will be calculated based on the gross recovery, before expenses are deducted. This contingency fee is not set by law but is negotiable between the Attorney and Client. In the event there is no recovery, Client owes the Firms nothing.
4. EXPENSES PAID BY THE FIRMS. The Firms agree to advance any and all reasonable expenses associated with the prosecution of client’s claim. Expenses advanced by the Firms will be repaid to them from any recoveries mad. Ien the event no recovery is made, no repayment of expenses advanced will be required. Advanced expenses that shall be reimbursed include office expenses attributable to the representation, other than general overhead expenses. Such reimbursable office expenses shall include, but are not limited to, internal document copying and scanning at $0.25 per page, document copying and scanning performed by others, photograph, video and document imaging expenses and reproduction thereof, mileage at the rate allowed by the Internal Revenue Service, travel, and all airfare, mileage, legal research and investigation charges, long distance telephone charges, fax and electronic mail expense and postage. The reimbursable expenses will also include any and all expenses or costs paid to or for persons, entities or businesses outside the firm which are related to the representation, including but not limited to, experts and their staffs; jury consultants; specialized legal counsel for bankruptcy proceedings initiated by defendants; Medicare/Medicaid, hospital lien, and subrogation resolution services; interpreters; investigators; court reporters; videographers; and document imaging companies and personnelR. egardless of outcome, Client will be responsible for all medical bills and liens incurred as a result of medical treatment receiCvleiden. t understands the Firms may be representing multiple clients and agrees that in representing multiple clients many of the expenses incurred are common case expenses, which are costs and expenses incurred for the benefit of multiple clients, including expert witness fees, depositions of defendants, experts, and non-party witnesses, settlement conferences, trial expenses, filing fees, copy costs, and other expenses that are incurred for purposes of influencing the outcome of multiple clients’ claimsC. lient agrees the expenses that I am required to reimburse, if there is a recovery, include not only expenses for my own claims, but also the common case expenses. Any Common Benefit fees or awards earned by or paid to Watts Guerra LLC or Watts Guerra LLP will not be considered attorney’s fees under this agreement, will not be shared among the Firms, and will be the sole property of Watts Guerra LLC or Watts Guerra LLP.
5. MULTIPLE CLIENTS. Client understands and agrees that the Firms may be representing more than one client in this matter and that the following aspects of joint representation have been disclosed: (1) the Client might gain or lose some advantages if represented by separate counsel; (2) the Firms cannot serve as an advocate for one client against another client; (3) the Firms must deal impartially with every client; (4) information received by the Firms from or on behalf of any jointly represented client concerning the matter may not be confidential or privileged as between the jointly-represented clients; and (5) if a conflict arises between clients, the Firms might not be able to continue representing any of the clients involved. Client consents to the Firms representing more than one client in this matter.
6. LAW AND VENUE. T his agreement shall be governed by and interpreted under eTxas substantive law, and exclusive venue and jurisdiction of any lawsuit or claim arising out of or relating to this agreement shall lie inex Tas State Court in Bexar County, Texas. If any provision of this agreement shall be held to be invalid, illegal, unenforceable or in conflict with the law of any jurisdiction, the , validity legality and enforceability of the remaining provisions shall not in any way be affected or impaired thereby.
7. NO SOLICITATION OF CLIENT. By signing and entering into this agreement, Client hereby affirms that Client’s case was not solicited by the Firms, the agreement is not being entered into as a result of promises of mon, enyo promises of a successful recovery have been made to Client, and Client has freely and voluntarily entered into this agreement.
READ AND ACCEPTED BY:

CLIENT NAME:

CLIENT MAIN EMAIL:

MAILING ADDRESS:

CITY, STATE, ZIP CODE: , ,

CLIENT PHONE NUMBER:

IDENTITY OF CLIENTS: Please provide the full legal name, and date of birth, of eligible Child. CHILD NAME:
DATE OF BIRTH:
CONTRACT OF EMPLOYMENT AND CONSENT TO FEE SHARING (TOPAMAX® LITIGATION)

By this Agreement (this “Agreement”), employs the Watts Guerra LLC, Watts Guerra LLP, Sunridge Law Group, LLC, and the Law Office of Douglas Boxer called “the Firms,” on behalf of Client and Client’s child (collectively, “Client”) to serve as Client’s attorneys for the sole purpose of prosecuting Client’s claims against those responsible for the manufacture and distribution of the Topamax® taken by Client during her pregnancy with Client’s child, which Topamax® caused Client’s child to suffer autism spectrum disorder (collectively, Client’s “Claims”).

1. THE FIRMS’ AUTHORITY. Client fully authorizes and directs the Firms to manage and handle my claims as they deem proper and to investigate and prosecute them, with or without filing a lawsuit, in any manner they deem advisable. Client authorizes the Firms to deliver in my name any and all notices, receipts, authorizations, releases, pleadings and any other documents proper in and to the handling of my claims. Client authorizes the Firms to use their professional judgment and any relevant documents, records, or other information that the Firms deem necessary to proper representation of Client. If, at any time, the Firms determine, for any permissible reason, that prosecution of Client’s claims should be discontinued, the Firms may withdraw from my representation. Client understands and agrees that the Firms may transmit Client’s protected health information electronically in the course of representing Client. The Firms do not provide tax advice.
2. CLIENT’S COOPERATION. Client agrees to cooperate fully with the Firms, disclose all relevant facts and promptly advise the Firms of any change in address or telephone number, and to promptly comply with all reasonable requests of the Firms on all matters related to this contract. Client consents to being contacted by the Firms via telephone, text message, email, and specifically through the use of robocall technology as well as any other necessary methods of communication. Client understands that failure to fully cooperate may be a basis for termination of this contract. Client agrees not to attempt on his/her part to unilaterally settle the claims made the subject of this contract. The Client will rely exclusively upon the representation of the Firms during any settlement negotiations. No settlement will be made without the Client's consent.
3. CONTINGENT FEE ARRANGEMENT. The Firms will assume joint responsibility for Client’s representation. In consideration of such legal services, Client hereby assigns and grants to the Firms the following percentage of any monies, interest, settlement, judgment, Court awarded costs or attorney fees or property recovered: FORTY PERCENT (40%). Client consents to the Firms’ sharing these attorneys’ fees 2.25% to the Law Office of Douglas Boxer, 47.5% to Watts Guerra LLC, 2.5% to Watts Guerra LLP, 27.75% to Sunridge Law Group, LLC and 20% to . Client consents to the Firms sharing their attorneys’ fees with local counsel as necessary. Attorneys’ fees will be determined before repayment of expenses; that is, attorneys’ fees will be calculated based on the gross recovery, before expenses are deducted. This contingency fee is not set by law but is negotiable between the Attorney and Client. In the event there is no recovery, the Client owes the Firms nothing.
4. EXPENSES PAID BY THE FIRMS. The Firms agree to advance any and all reasonable expenses associated with the prosecution of the client's claim. Expenses advanced by the Firms will be repaid to them from any recoveries made. In the event no recovery is made, no repayment of expenses advanced will be required. Advanced expenses that shall be reimbursed include office expenses attributable to the representation, other than general overhead expenses. Such reimbursable office expenses shall include, but are not limited to, internal document copying and scanning at $0.25 per page, document copying and scanning performed by others, photograph, video and document imaging expenses and reproduction thereof, mileage at the rate allowed by the Internal Revenue Service, travel, and all airfare, mileage, legal research and investigation charges, long distance telephone charges, fax and electronic mail expense and postage. The reimbursable expenses will also include any and all expenses or costs paid to or for persons, entities or businesses outside the firm which are related to the representation, including but not limited to, experts and their staffs; jury consultants; specialized legal counsel for bankruptcy proceedings initiated by defendants; Medicare/Medicaid, hospital lien, and subrogation resolution services; interpreters; investigators; court reporters; videographers; and document imaging companies and personnel. Regardless of outcome, Client will be responsible for all medical bills and liens incurred as a result of medical treatment received. Client understands the Firms may be representing multiple clients and agrees that in representing multiple clients many of the expenses incurred are common case expenses, which are costs and expenses incurred for the benefit of multiple clients, including expert witness fees, depositions of defendants, experts, and non-party witnesses, settlement conferences, trial expenses, filing fees, copy costs, and other expenses that are incurred for purposes of influencing the outcome of multiple clients’ claims. Client agrees the expenses that I am required to reimburse, if there is a recovery, include not only expenses for my own claims, but also the common case expenses. Any Common Benefit fees or awards earned by or paid to Watts Guerra LLC or Watts Guerra LLP will not be considered attorney’s fees under this agreement, will not be shared among the Firms, and will be the sole property of Watts Guerra LLC or Watts Guerra LLP.
5. MULTIPLE CLIENTS. Client understands and agrees that the Firms may be representing more than one client in this matter and that the following aspects of joint representation have been disclosed: (1) the Client might gain or lose some advantages if represented by separate counsel; (2) the Firms cannot serve as an advocate for one client against another client; (3) the Firms must deal impartially with every client; (4) information received by the Firms from or on behalf of any jointly represented client concerning the matter may not be confidential or privileged as between the jointly-represented clients; and (5) if a conflict arises between clients, the Firms might not be able to continue representing any of the clients involved. Client consents to the Firms representing more than one client in this matter.
6. LAW AND VENUE. This agreement shall be governed by and interpreted under Texas substantive law, and exclusive venue and jurisdiction of any lawsuit or claim arising out of or relating to this agreement shall lie in Texas State Court in Bexar County, Texas. If any provision of this agreement shall be held to be invalid, illegal, unenforceable or in conflict with the law of any jurisdiction, the validity, legality and enforceability of the remaining provisions shall not in any way be affected or impaired thereby.
7. NO SOLICITATION OF CLIENT. By signing and entering into this agreement, Client hereby affirms that Client’s case was not solicited by the Firms, the agreement is not being entered into as a result of promises of money, no promises of a successful recovery have been made to Client, and Client has freely and voluntarily entered into this agreement.
8. CLIENT ACKNOWLEDGEMENT: Client acknowledges that Client has read and understood the foregoing terms of this Agreement and agrees to them.
READ AND ACCEPTED BY:

CLIENT NAME:

CLIENT MAIN EMAIL:

MAILING ADDRESS:

CITY, STATE, ZIP CODE: , ,

CLIENT PHONE NUMBER:

IDENTITY OF CLIENTS: Please provide the full legal name, and date of birth, of eligible Child. CHILD NAME:
DATE OF BIRTH:
CONTRACT OF EMPLOYMENT AND CONSENT TO FEE SHARING (ACETAMINOPHEN LITIGATION)
By this Agreement (this “Agreement”), employs Watts Guerra LLC, Watts Guerra LLP, Sunridge Law Group, LLC, the Law Office of Douglas Boxer called “the Firms,” on behalf of Client and Client’s minor child (collectively, “Client”) as my attorneys to represent me in all claims, suits, or other matters against those responsible for the manufacture and distribution of the acetaminophen taken by Client during her pregnancy with Client’s minor child, which acetaminophen caused Client’s minor child to suffer autism spectrum disorder (collectively, Client’s “Claims”).
1. THE FIRMS’ AUTHORITY. Client fully authorizes and directs the Firms to manage and handle my claims as they deem proper and to investigate and prosecute them, with or without filing a lawsuit, in any manner they deem advisable. Client authorizes the Firms to deliver in my name any and all notices, receipts, authorizations, releases, pleadings and any other documents proper in and to the handling of my claims. Client authorizes the Firms to use their professional judgment and any relevant documents, records, or other information that the Firms deem necessary to proper representation of Client. If, at any time, the Firms determine, for any permissible reason, that prosecution of Client’s claims should be discontinued, the Firms may withdraw from my representation. Client understands and agrees that the Firms may transmit Client’s protected health information electronically in the course of representing Client. The Firms do not provide tax advice.
2. CLIENT’S COOPERATION. Client agrees to cooperate fully with the Firms, disclose all relevant facts and promptly advise the Firms of any change in address or telephone number, and to promptly comply with all reasonable requests of the Firms on all matters related to this contract. Client consents to being contacted by the Firms via telephone, text message, email, and specifically through the use of robocall technology as well as any other necessary methods of communication. Client understands that failure to fully cooperate may be a basis for termination of this contract. Client agrees not to attempt on his/her part to unilaterally settle the claims made the subject of this contract. The Client will rely exclusively upon the representation of the Firms during any settlement negotiatNioon sse. ttlement will be made without the Client's consent.
3. CONTINGENT FEE ARRANGEMENT. The Firms will assume joint responsibility for Client’s representation. In consideration of such legal services, Client hereby assigns and grants to the Firms the following percentage of any monies, interest, settlement, judgment, Court awarded costs or attorney fees or property recovered: FORTY PERCENT (40%). Client consents to the Firms’ sharing these attorneys’ fees 2.25% to the Law Office of Douglas Boxer, 47.5% to Watts Guerra LLC, 2.5% to Watts Guerra LLP, 47.75% to Sunridge Law Group, LLC. Client consents to the Firms sharing their attorneys’ fees with local counsel as necessary. Attorneys’ fees will be determined before repayment of expenses; that is, attorneys’ fees will be calculated based on the gross recovery, before expenses are deducted. This contingency fee is not set by law but is negotiable between the Attorney and Client. In the event there is no recovery, Client owes the Firms nothing.
4. EXPENSES PAID BY THE FIRMS. The Firms agree to advance any and all reasonable expenses associated with the prosecution of client’s claim. Expenses advanced by the Firms will be repaid to them from any recoveries mad. Ien the event no recovery is made, no repayment of expenses advanced will be required. Advanced expenses that shall be reimbursed include office expenses attributable to the representation, other than general overhead expenses. Such reimbursable office expenses shall include, but are not limited to, internal document copying and scanning at $0.25 per page, document copying and scanning performed by others, photograph, video and document imaging expenses and reproduction thereof, mileage at the rate allowed by the Internal Revenue Service, travel, and all airfare, mileage, legal research and investigation charges, long distance telephone charges, fax and electronic mail expense and postage. The reimbursable expenses will also include any and all expenses or costs paid to or for persons, entities or businesses outside the firm which are related to the representation, including but not limited to, experts and their staffs; jury consultants; specialized legal counsel for bankruptcy proceedings initiated by defendants; Medicare/Medicaid, hospital lien, and subrogation resolution services; interpreters; investigators; court reporters; videographers; and document imaging companies and personnelR. egardless of outcome, Client will be responsible for all medical bills and liens incurred as a result of medical treatment receiCvleiden. t understands the Firms may be representing multiple clients and agrees that in representing multiple clients many of the expenses incurred are common case expenses, which are costs and expenses incurred for the benefit of multiple clients, including expert witness fees, depositions of defendants, experts, and non-party witnesses, settlement conferences, trial expenses, filing fees, copy costs, and other expenses that are incurred for purposes of influencing the outcome of multiple clients’ claimsC. lient agrees the expenses that I am required to reimburse, if there is a recovery, include not only expenses for my own claims, but also the common case expenses. Any Common Benefit fees or awards earned by or paid to Watts Guerra LLC or Watts Guerra LLP will not be considered attorney’s fees under this agreement, will not be shared among the Firms, and will be the sole property of Watts Guerra LLC or Watts Guerra LLP..
5. MULTIPLE CLIENTS. Client understands and agrees that the Firms may be representing more than one client in this matter and that the following aspects of joint representation have been disclosed: (1) the Client might gain or lose some advantages if represented by separate counsel; (2) the Firms cannot serve as an advocate for one client against another client; (3) the Firms must deal impartially with every client; (4) information received by the Firms from or on behalf of any jointly represented client concerning the matter may not be confidential or privileged as between the jointly-represented clients; and (5) if a conflict arises between clients, the Firms might not be able to continue representing any of the clients involved. Client consents to the Firms representing more than one client in this matter.
6. LAW AND VENUE. This agreement shall be governed by and interpreted under Texas substantive law, and exclusive venue and jurisdiction of any lawsuit or claim arising out of or relating to this agreement shall lie inex Tas State Court in Bexar County, Texas. If any provision of this agreement shall be held to be invalid, illegal, unenforceable or in conflict with the law of any jurisdiction, the vali,d ity legality and enforceability of the remaining provisions shall not in any way be affected or impaired thereby.
7. NO SOLICITATION OF CLIENT. By signing and entering into this agreement, Client hereby affirms that Client’s case was not solicited by the Firms, the agreement is not being entered into as a result of promises of mon, enyo promises of a successful recovery have been made to Client, and Client has freely and voluntarily entered into this agreement.
READ AND ACCEPTED BY:

CLIENT NAME:

CLIENT MAIN EMAIL:

MAILING ADDRESS:

CITY, STATE, ZIP CODE: , ,

CLIENT PHONE NUMBER:

IDENTITY OF CLIENTS: Please provide the full legal name, and date of birth, of eligible Child. CHILD NAME:
DATE OF BIRTH:
CONTRACT OF EMPLOYMENT AND CONSENT TO FEE SHARING (ACETAMINOPHEN LITIGATION)
The undersigned “Clients”: (client’s printed name; or if deceased, name of client and decedent as: (client) individually and as representative of the estate and/or the successor in interest of (decedent)), hereby employs the Watts Guerra LLC, Watts Guerra LLP, Sunridge Law Group, LLC, the Law Office of Douglas Boxer called “the Firms,” and as my attorneys to represent me in all claims, suits, or other matters against those responsible for the manufacture and distribution of the acetaminophen taken by Client during her pregnancy with Client’s minor child, which acetaminophen caused Client’s minor child to suffer autism spectrum disorder (collectively, Client’s “Claims”).
1. THE FIRMS’ AUTHORITY. Client fully authorizes and directs the Firms to manage and handle my claims as they deem proper and to investigate and prosecute them, with or without filing a lawsuit, in any manner they deem advisable. Client authorizes the Firms to deliver in my name any and all notices, receipts, authorizations, releases, pleadings and any other documents proper in and to the handling of my claims. Client authorizes the Firms to use their professional judgment and any relevant documents, records, or other information that the Firms deem necessary to proper representation of Client. If, at any time, the Firms determine, for any permissible reason, that prosecution of Client’s claims should be discontinued, the Firms may withdraw from my representation. Client understands and agrees that the Firms may transmit Client’s protected health information electronically in the course of representing Client. The Firms do not provide tax advice.
2. CLIENT’S COOPERATION. Client agrees to cooperate fully with the Firms, disclose all relevant facts and promptly advise the Firms of any change in address or telephone number, and to promptly comply with all reasonable requests of the Firms on all matters related to this contract. Client consents to being contacted by the Firms via telephone, text message, email, and specifically through the use of robocall technology as well as any other necessary methods of communication. Client understands that failure to fully cooperate may be a basis for termination of this contract. Client agrees not to attempt on his/her part to unilaterally settle the claims made the subject of this contract. The Client will rely exclusively upon the representation of the Firms during any settlement negotiations. No settlement will be made without the Client's consent.
3. CONTINGENT FEE ARRANGEMENT. The Firms will assume joint responsibility for Client’s representation. In consideration of such legal services, Client hereby assigns and grants to the Firms the following percentage of any monies, interest, settlement, judgment, Court awarded costs or attorney fees or property recovered: FORTY PERCENT (40%). Client consents to the Firms’ sharing these attorneys’ fees 2.25% to the Law Office of Douglas Boxer, 47.5% to Watts Guerra LLC, 2.5% to Watts Guerra LLP, 27.75% to Sunridge Law Group, LLC, and 20% to . Client consents to the Firms sharing their attorneys’ fees with local counsel as necessary. Attorneys’ fees will be determined before repayment of expenses; that is, attorneys’ fees will be calculated based on the gross recovery, before expenses are deducted. This contingency fee is not set by law but is negotiable between the Attorney and Client. In the event there is no recovery, Client owes the Firms nothing.
4. EXPENSES PAID BY THE FIRMS. The Firms agree to advance any and all reasonable expenses associated with the prosecution of client’s claim. Expenses advanced by the Firms will be repaid to them from any recoveries made. In the event no recovery is made, no repayment of expenses advanced will be required. Advanced expenses that shall be reimbursed include office expenses attributable to the representation, other than general overhead expenses. Such reimbursable office expenses shall include, but are not limited to, internal document copying and scanning at $0.25 per page, document copying and scanning performed by others, photograph, video and document imaging expenses and reproduction thereof, mileage at the rate allowed by the Internal Revenue Service, travel, and all airfare,mileage, legal research and investigation charges, long distance telephone charges, fax and electronic mail expense and postage. The reimbursable expenses will also include any and all expenses or costs paid to or for persons, entities or businesses outside the firm which are related to the representation, including but not limited to, experts and their staffs; jury consultants; specialized legal counsel for bankruptcy proceedings initiated by defendants; Medicare/Medicaid, hospital lien, and subrogation resolution services; interpreters; investigators; court reporters; videographers; and document imaging companies and personnelR. egardless of outcome, Client will be responsible for all medical bills and liens incurred as a result of medical treatment receiCvleiden. t understands the Firms may be representing multiple clients and agrees that in representing multiple clients many of the expenses incurred are common case expenses, which are costs and expenses incurred for the benefit of multiple clients, including expert witness fees, depositions of defendants, experts, and non-party witnesses, settlement conferences, trial expenses, filing fees, copy costs, and other expenses that are incurred for purposes of influencing the outcome of multiple clients’ claims. Client agrees the expenses that I am required to reimburse, if there is a recovery, include not only expenses for my own claims, but also the common case expe.n Asensy Common Benefit fees or awards earned by or paid to Watts Guerra LLC or Watts Guerra LLP will not be considered attorney’s fees under this agreement, will not be shared among the Firms, and will be the sole property of Watts Guerra LLC or Watts Guerra LLP.
5. MULTIPLE CLIENTS. Client understands and agrees that the Firms may be representing more than one client in this matter and that the following aspects of joint representation have been disclosed: (1) the Client might gain or lose some advantages if represented by separate counsel; (2) the Firms cannot serve as an advocate for one client against another client; (3) the Firms must deal impartially with every client; (4) information received by the Firms from or on behalf of any jointly represented client concerning the matter may not be confidential or privileged as between the jointly-represented clients; and (5) if a conflict arises between clients, the Firms might not be able to continue representing any of the clients involvedC.l ient consents to the Firms representing more than one client in this matter.
6. LAW AND VENUE. This agreement shall be governed by and interpreted under eTxas substantive law, and exclusive venue and jurisdiction of any lawsuit or claim arising out of or relating to this agreement shall lie in Texas State Court in Bexar County, Texas. If any provision of this agreement shall be held to be invalid, illegal, unenforceable or in conflict with the law of any jurisdiction, the validity, legality and enforceability of the remaining provisions shall not in any way be affected or impaired thereby.
7. NO SOLICITATION OF CLIENT. By signing and entering into this agreement, Client hereby affirms that Client’s case was not solicited by the Firms, the agreement is not being entered into as a result of promises of mon, enyo promises of a successful recovery have been made to Client, and Client has freely and voluntarily entered into this agreement.
8. CLIENT ACKNOWLEDGEMENT: Client acknowledges that Client has read and understood the foregoing terms of this Agreement and agrees to them.
READ AND ACCEPTED BY:

CLIENT NAME:

CLIENT MAIN EMAIL:

MAILING ADDRESS:

CITY, STATE, ZIP CODE: , ,

CLIENT PHONE NUMBER:

IDENTITY OF CLIENTS: Please provide the full legal name, and date of birth, of eligible Child. CHILD NAME:
DATE OF BIRTH:
Contract Approved and Accepted Date
Client Date of Birth
Client Address*

's Social Security Number:

You may provide the last 4 digits if you are uncomfortable sharing.

's Social Security Number:

You may provide the last 4 digits if you are uncomfortable sharing.
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Power of Attorney

POWER OF ATTORNEY

STATE OF   *

                                             *       KNOW ALL MEN BY THESE PRESENTS:

COUNTY OF   *


         That I, , individually and as representative and/or successor in interest for have made, constituted, and appointed, and do so by this instrument hereby make, constitute, empower, and appoint, Mikal C. Watts, WATTS GUERRA LLC, Attorneys at Law, or representatives of WATTS GUERRA LLC (collectively, my “attorneys”), 5726 W Hausman Rd, Suite 119, San Antonio, Texas 78249, as my true and lawful attorneys for me and give my attorneys and or representatives the powers listed below to act in my name, place, and stead to appear for and represent me in the claims involving Topamax giving my said attorneys full power to do everything whatsoever requisite and necessary and in any way which I, myself, could do if I were personally present.


My attorneys’ powers shall include the power to: (a) take any and all steps necessary to request and collect medical and pharmacy records related to my representation; (b) take any and all steps necessary to request and collect any and all mental health records related to my representation; (c) take any and all actions necessary to resolve issues with ordering medical and or pharmaceutical records, including signing my name to medical, pharmacy, Health Insurance Portability and Accountability Act of 1996 (HIPAA), and similar authorizations, or otherwise digitally affixing a copy of my signature to said authorizations, in order to obtain medical and pharmaceutical records related to my representation; (d) take any and all actions necessary to verify, affirm, and or attest to discovery responses in my lawsuit, including plaintiff fact sheets or similar requests, including signing my name to said discovery documents, or otherwise digitally affixing a copy of my signature to said documents; and (e) take any and all actions necessary to identify and resolve liens that are or might be asserted related to my injuries, including, but not limited to Medicare, Medicaid, insurance, workers compensation, and or other health care related liens, by signing my name or otherwise digitally affixing a copy of my signature to documents retaining, and otherwise utilizing, specialized lien resolution groups to assist in said matters.


            It is understood and agreed that the attorneys’ fees in my case are governed by and are subject to the attorney Employment Contract entered into between WATTS GUERRA LLC and myself, and further, no settlement will be made without my consent. This Power of Attorney shall become effective immediately upon execution; however, I may revoke this power of attorney at any time by providing written notice to my Attorneys.


I agree that any third party who receives a copy of this document may act under it. Revocation of this power of attorney is not effective as to a third party until the third party receives actual notice of the revocation. I agree to indemnify the third party for any claims that arise against the third party because of reliance on this power of attorney.

IN TESTIMONY WHEREOF, I have hereunto set my signature at:
:  
State (POA)
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Authorization for Disclosure of Protected Health Information (HIPAA)

AUTHORIZATION FOR USE & DISCLOSURE OF INDIVIDUALLY IDENTIFIABLE AND PROTECTED HEALTH INFORMATION (“HEALTH INFORMATION”)


1. PATIENT IDENTIFICATION

PRINTED NAME:

DATE OF BIRTH:

SOCIAL SECURITY NUMBER:


2. PATIENT ADDRESSES

ADDRESS (Current Residence):

CITY: STATE: ZIP:


ADDRESS (Time of Treatment/Prescription):

CITY: ____________________________ STATE: ______ ZIP:___________________________


3. PERSONS/ORGANIZATIONS AUTHORIZED TO DISCLOSE HEALTH INFORMATION: (hereinafter referred to as “Custodian Of Records”):


4. PERIODS OF HEALTH CARE/HEALTH INFORMATION/ACADEMIC INFORMATION TO BE DISCLOSED

By signing, I authorize the Custodian of Records to release my medical or billing records containing information in reference to: Communicable and Non-Communicable Diseases, and/or Drug and/or Alcohol Abuse, and/or Psychiatric, and/or HIV/AIDS Records.


Date (From): _____________ Date (To): _________________
Date (From): _____________ Date (To): _________________


HOSPITAL MEDICAL RECORDS:

___Complete Inpatient and Outpatient Health Record

___Emergency Room Record
___History & Physical Exam
___Discharge Summary

___Consultation Reports
___Progress Notes
___Laboratory Test Results

___Radiology Reports
___Radiology Studies (Films & Images) to Match Attached Reports

___Operative Reports
___Pathology Reports
___Pathology Slides

___Photographs, Videotapes

___Abstract of Health Record (All Transcribed Physician Reports & Test Results)


MEDICAL RECORDS:

___Complete Emergency Medical Transport & Health Record

___Complete Autopsy Report, Autopsy Photographs, & Toxicology Report
___Complete Health Record from Physician’s Office* or Clinic* or Chiropractor* or Acupuncturist
___Complete Pharmacy/Prescription Record

___Complete Rehabilitation/Physical/Occupational/Recreational/Speech Therapy Record*

___Complete Psychiatric, Psychological, Licensed Clinical Social Worker, Mental Health Counselor/Therapist Record and associated Testing*

___Complete Home Health/Nursing Record*
___Complete Nursing Home Record*

___Complete Funeral Home Record

___Complete Durable Medical Equipment Record/Medical Supply Record*

___Complete Prosthetic Equipment & Fitting Record*

___Complete Dental Record*

___Radiology Reports*
___Radiology Studies (Films & Images)

___Laboratory Test Results*
___Pathology Reports*
___Pathology Slides

___Photographs, Videotapes, Digital Images

___Other


• Including records/documents received from any other health care providers, therapists, or counselors.


BILLING RECORDS:

___Complete Billing Record including an Itemized Statement


5. TO WHOM AND WHERE TO SEND DISCLOSED HEALTH INFORMATION:

I authorize the disclosure and use of the Health Information described above to the following person(s) or organization(s):


SEND INFORMATION TO:

Watts Guerra LLC

AS AGENT FOR 5726 W Hausman Rd Ste 119

San Antonio, TX 78249

866.529.9100


6. PURPOSE OF DISCLOSURE/USE:
CIVIL LITIGATION


7. RE-DISCLOSURE:

I understand the information disclosed by this Authorization may be subject to re-disclosure by the recipients and no longer be protected by the Health Insurance Portability and Accountability Act of 1996. The facilities, their employees and officers are hereby released from any legal responsibility or liability for disclosure of the above information to the extent indicated and authorized herein.


8. LIMIT & RIGHT TO REVOKE AUTHORIZATION:

Except to the extent that action has already been taken in reliance on this Authorization, I understand this Authorization is voluntary and that I may revoke it at any time by submitting a notice in writing to the Custodian of Records or organization(s) providing the Protected Health Information. Unless revoked this Authorization will expire on the following date or event: upon completion of pending civil litigation.


Expiration date/event is further defined as resolution of the claim asserted or at the conclusion of any litigation instituted in connection with the subject matter of pending civil litigation and/or of the Notice of the Health Care Claim. Treatment, payment, enrollment in a health plan, or eligibility for health insurance benefits may not be conditioned on my signing this authorization.


9. The office of WATTS GUERRA, is authorized to discuss with any health care provider, therapist, individual, fiduciary, agent, or other person any evidence, testimony or fact deemed by said attorneys to be material, and said attorneys and their agents are authorized to examine, inspect, copy, and/or inquire of any person, firm, corporation, institution or agency thereof concerning or relating to any evidence, documents, reports, and/or records. All such persons are requested to freely cooperate with said attorneys or their agents.


10. The Custodian of Records is released from any legal responsibility for the disclosure of the above stated Health Information to the extent indicated and authorized herein.


11. A facsimile, photostatic, carbon or other copies of this Authorization are intended and shall be treated as an original.


12. I understand that the health information described above may be transmitted electronically and may be redisclosed electronically by WATTS GUERRA.


13. RIGHTS & SIGNATURE OF PATIENT OR PERSONAL REPRESENTATIVE REQUESTING DISCLOSURE:

I understand that I do not have to sign this Authorization and that my treatment or payment for services will not be denied if I do not sign this form unless specified above under Purpose of Request. I can inspect or copy the Health Information to be used or disclosed. I may see and receive a copy of this Authorization. I authorize the Custodian of Records to disclose the Health Information specified above. The information I am requesting may be sent by U.S. mail service, expedited mail services (such as Federal Express, Lone Star, etc.) and/or electronic facsimile in accordance with the provider’s facsimile policy.


**If you are signing as a PERSONAL REPRESENATIVE of another person, you MUST provide a description of your authority to act for the other person (for example, a Power of Attorney), and a copy of the document, if any, that authorizes you to act as the patient’s personal representative.

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HIPAA Date

FERPA - CONSENT TO RELEASE STUDENT INFORMATION

Address of School*

Please provide all information from the educational records of , below, to Watts Guerra LLC:

(Note: this Consent covers medical records held by the school)

 

The information that is to be released under this consent includes: 

• transcripts  

• disciplinary records 

• recommendations for employment or admission to other schools 

• all records of special education, assessment, and intervention. 

• and other (specify)  Contacts and interactions with counselors or peer leaders. 

 

The information is to be released for legal purposes: 

 

I  understand  the  information  may  be  released  orally  or  in  the  form  of  copies  of  written  records,  as preferred by the requester. I have a right to inspect any written records released pursuant to this Consent (except for parents’ financial records and certain letters of recommendation for which the student waived inspection rights). I understand I may revoke this Consent upon providing written notice to the custodian of these records. I further understand that until this revocation is made, this consent shall remain in effect and my educational records will continue to be provided to Rapid Record Retrieval for the specific purpose described above.

Relationship to :*

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Declaration

CONFIDENTIAL DOCUMENT 

SUBJECT TO FRE 408 AND STATE EQUIVALENT DECLARATION

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that all of the information provided in connection with this Declaration is true and correct to the best of my knowledge, information, and belief. My child has been diagnosed by a medical professional with Autism Spectrum Disorder and/or an Intellectual Disability. I took Topamax during my pregnancy with my child.


CONFIDENTIAL DOCUMENT 

SUBJECT TO FRE 408 AND STATE EQUIVALENT


DECLARATION


Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that all of the information provided in connection with this Declaration is true and correct to the best of my knowledge, information, and belief. My child, , has been diagnosed by a medical professional with Autism Spectrum Disorder. I took acetaminophen-containing products, as identified by me on the attached chart, during my pregnancy with .


I took one or more of the identified forms of acetaminophen-containing products during my pregnancy with in the following frequencies and/or dosages:

  • During any 20 weeks while pregnant; OR
  • During any 10 weeks while pregnant with at least one of those 10 weeks being in the first trimester, at least one being in the second trimester, and one being in the third trimester; OR
  • 16 or more times (at least 16 pills or a total of 5000mgs) cumulatively while pregnant.
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Declaration Date

Documents Signed - Next Steps

Thank you for trusting us to represent you and work on your claim. We will be here with you every step of the way. The last thing we need to do for now is gather additional background information so our team can begin to order medical records and gather evidence to support your case. 


It is critical that you complete this entire section. If this section is not completed, unfortunately all previous sections will not be submitted to us. If you are unsure about certain questions, that is OK. Please provide your best estimate. If you prefer to go through everything with one of our case managers, you can always call us at (866) 360-8949. Please know that they will need to start from the beginning with you in order to ensure all information is accurate. Let’s get started.

Mother's Personal Information

Mother's Date of Birth*
Mother's Street Address*
Stage 4 - Long Form Started
Father's Date of Birth*

Secondary Contact Information

Alternative Contact's Address

Mother's Medical Information

Street Address of Facility:*

Mother's Medical Information

Have you ever had any side-effects from Topamax?*

What other medications did the doctor prescribe and did you take while pregnant with ?*

Did any other doctors prescribe you Topamax?*

Mother's Medical Information

What is the address of the SECOND facility?*

Mother's Medical Information

Have you ever had any side-effects from the SECOND Topamax prescription?*

What other medications did the doctor prescribe and did you take while pregnant with ?*

Mother's Medical Information

Are you still taking Topamax?*
Note: please enter a 4 digit year value.

Pharmacy Information

Pharmacy Street Address*
Did you pick-up Topamax from any other pharmacies?*

Pharmacy Information

What is the address of the SECOND Pharmacy that filled your prescription for Topamax?*

Trimester Details

About how many times did you take Topamax during your FIRST trimester?*
About how many times did you take Topamax during your SECOND trimester?*
About how many times did you take Topamax during your THIRD trimester?*

First Trimester Details

If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
About how many times did you take acetaminophen during your FIRST trimester?*

Second Trimester Details

If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
About how many times did you take acetaminophen during your SECOND trimester?*

Third Trimester Details

If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
If unsure, choose the brand that you would have most likely taken.
If unsure, choose the product that you would have most likely taken.
For example, 50% Tylenol and 50% Safeway Signature Care Acetaminophen.
About how many times did you take acetaminophen during your THIRD trimester?*

Additional Information at Time of Birth

Weight is in pounds / lbs
Were you diagnosed with any of the following major medical conditions during this pregnancy?*

Additional Information at Time of Birth

How was your baby delivered?*

Was ’s birth traumatic or did it result in loss of oxygen or injury to ?*

If ’s birth was traumatic or resulted in loss of oxygen or injury to , please describe in as much detail as possible what occurred:*

Child's Diagnosis Information

What was the approximate date was diagnosed with autism?*

What was the approximate date received an IEP for autism?*

Do they still have an IEP for autism?*

What was the approximate date started receiving early intervention services for autism?*

Are they still receiving early intervention services for autism?*

What was the approximate date was diagnosed with Intellectual Disability?*

Child's Diagnosis Information

Has your child been diagnosed with any other conditions other than autism or an intellectual disability?*

Child's Diagnosis Information (cont'd)

Does have developmental delays? Communicate verbally?*

Please provide as much detail as possible related to development delays.

Does display any repetitive movements (i.e., stimming), such as flapping their hands, rocking back and forth, or spinning?*

Please provide as much detail as possible.

Does have an IEP, 504, or other accommodation for any condition other than Autism or an intellectual disability?*

Please provide as much detail as possible.

Primary Diagnosis Providers

Provider's Address*
Date of diagnosis:*
Was there another facility where diagnosis occurred?*

Primary Diagnosis Providers - Second Provider

SECOND Provider's Address*
Date of SECOND Diagnosis:*

Treatment Providers

How many treatment facilities has gone to?

Address of FIRST Treatment Facility*

Treatment Providers - Second Provider

Street Address of SECOND Treatment Facility:*

Treatment Providers - Third Provider

Street Address of THIRD Treatment Facility:*

Treatment Providers - Fourth Provider

Street Address of FOURTH Treatment Facility:*

Treatment Providers - Fifth Provider

Street Address of FIFTH Treatment Facility:*

IEP/Early Intervention Services Details

Address of School:*

Document Requests

If you are in possession of any of the following documents (or can get copies) please send to mtintake@wattsguerra.com:


  1. Copies (or pictures) of the packaging, including the bottle, box, label, product inserts, for Topamax you took during your pregnancy
  2. Copies of receipts for purchasing Topamax during your pregnancy with your child
  3. Copies of any medical or billing records from physicians or treatments centers relating to your exposure to Topamax;
  4. Copies of any medical or billing records from physicians for other healthcare providers related to your child’s ASD/ID diagnosis or severity;
  5. Copies of any records from child’s school relating to autism and/or intellectual disability and accommodations including by not limited to IEPs, 504s, counseling records, ARDs, and other materials. 
  6. Copies of any documents (i.e. instructions, warnings, advertisements) relating to Topamax obtained from your physician, pharmacy, or a newspaper or other advertisement; and
  7. If the injured party is deceased, copies of any death certificate, last will, and or probate documents.

If you are in possession of any of the following documents (or can get copies) please send to mtintake@wattsguerra.com:


  1. Copies (or pictures) of the packaging, including the bottle, box, label, product inserts, for acetaminophen-containing products you took during your pregnancy with your child with ASD;
  2. Copies of receipts for purchasing acetaminophen-containing products during your pregnancy with your child with ASD;
  3. Copies of any medical or billing records from physicians or treatments centers relating to your exposure to acetaminophen and your child’s diagnosis of ASD;
  4. Copies of any medical or billing records from physicians for other healthcare providers related to your child’s ASD diagnosis or severity;
  5. Copies of any records from child’s school relating to autism and accommodations including by not limited to IEPs, 504s, counseling records, ARDs, and other materials. 
  6. Copies of any documents (i.e. instructions, warnings, advertisements) relating to acetaminophen-containing products obtained from your physician, pharmacy, or a newspaper or other advertisement; and
  7. If the injured party is deceased, copies of any death certificate, last will, and or probate documents.