Don't forget to check your corporate defendant's website for useful tidbits--proper names, description of business practices and goals for use in pleadings and discovery, etc. Also, check out Archive.org for archived outdated versions of websites.

Do not release the primary tort-feasor. If you release the person primarily liable and proceed against one secondarily liable, you may end up liable. Barsh v. Mullins, 1959 OK 2, 338 P.2d 845. The release of the employee releases the employer, as a matter of law.

Make sure your clients know not to post information about their case on MySpace, Facebook, or similar websites. They should also make these sites "private" so as not to provide fodder for Defense attorneys who can and do check these sites for information to use against your clients.

Don’t forget to check homeowner’s policies for a one or two-year time to sue limitations. Depending on the circumstances, these provisions are valid and shorten the normal five-year contract SOL.

Let your clients know they may be followed by a private investigator with a camera–a few seconds of video can torpedo an otherwise good case.

Remember a homeowners’ policy’s liability coverage is not limited to incidents occurring on the insured’s premises.

Always find out if the adverse driver in an auto wreck case was "on-the-job." Company defendants usually have higher liability limits which may translate into a more complete financial recovery.

A named insured or resident family member does not have to be in the "insured vehicle" for UM to apply. They are covered when in another vehicle or even when "sitting on their porch swing" as long as they are entitled to to recover from the "owner or operator" of an unisured (or underinsured) vehicle or hit-and-run vehicle.

Be careful demanding punitives as a matter of course in your personal injury cases; punitive damages are taxable whereas compensatories usually are not. If you settle a case in which you demanded punitives, the IRS will want to allocate some of that recovery to the punitives claim triggering tax liability for your client. If you really have a claim for punitives, you can assert the claim later in time for trial.

Consider filing suit as soon as you take a case rather than waiting for negotiations to break down with a low ball offer from an adjuster; by the time your client finishes treatment, defense counsel has earned his fees and trial deadlines can encourage settlement offers.

Be sure to do a search for medical liens against your clients BI recovery before disbursing funds. The Supreme Court has ruled you owe an ethical obligation to be sure those liens are satisfied.

It may be possible to salvage a blown SOL in a state with a longer limitations period than Oklahoma's. I have saved more than one attorney from a malpractice suit in this way. Of course, you have to have a defendant amenable to personal jurisdiction in the state with the longer SOL. Sometimes, however, you can get away with having a defendant who doesn't understand jurisdiction and shows up and defends in the other state without raising a jurisdictional problem.

It may be possible to salvage a blown SOL in a state with a longer limitations period than Oklahoma's. I have saved more than one attorney from a malpractice suit in this way. Of course, you have to have a defendant amenable to personal jurisdiction in the state with the longer SOL. Sometimes, however, you can get away with having a defendant who doesn't understand jurisdiction and shows up and defends in the other state without raising a jurisdictional problem.

Don't forget under Oklahoma's "deeming statute" you don't usually have to sue your neighborhood insurance agent who screwed up your client's coverage. Just sue the big insurance company who will be liable under the statute for the agent's negligence.

If you're not up against a limitations problem, you may want to sue only your company defendant who employs the negligent driver involved in a wreck while on duty. You can always add the individual defendant later if the company denies scope of employment in its answer and in discovery.