An injury file can contain many pages and still leave a basic question unanswered: who or what can establish each material fact? A narrative, bill, photograph, witness note, medical entry, employer record, and technical opinion may address different questions and require different foundations.

A proof-source map should identify the fact to be established, the person or record with first-hand knowledge, the foundation for the source, any competing source, the qualified reviewer needed, and the question that remains unresolved.

Write the fact as a testable statement

  • One fact per row, with the person, event, date range, location, body part, amount, communication, policy, duty, or loss stated precisely
  • Why the fact matters to the current claim question without labeling it established in advance
  • Current status: supported, disputed, incomplete, contradicted, outside the source’s knowledge, or awaiting qualified review
  • The decision that depends on the fact and the deadline or dependency attached to that decision

Identify the source of personal knowledge

North Carolina Rule of Evidence 602 addresses a witness’s personal knowledge. For each person, record what the person actually saw, heard, felt, created, received, measured, or did, together with location, time, viewpoint, and limits.

Rule 701 addresses lay opinions or inferences. Preserve the observations behind an inference rather than replacing them with labels such as careless, disabled, dishonest, or permanently injured.

Map records to their creators and custodians

  • Record name, date range, account or claim identifier, creator, custodian, collection date, format, page or timestamp, and version
  • The particular field, entry, image, calculation, or communication that bears on the fact
  • Whether the entry came from the creator’s own knowledge or from another person who must be identified separately
  • Missing attachments, legends, code sheets, amendments, corrections, metadata, or predecessor records
  • Retention risk, request date, response, follow-up owner, and alternative source

Rule 803(6) describes conditions for records of regularly conducted activity. A record’s presence in a file does not itself establish those conditions or make every statement inside the record accurate. Rule 901 separately addresses authentication or identification.

Reserve technical conclusions for qualified review

Rule 702 addresses qualified expert testimony and its foundation. Diagnosis, medical causation, prognosis, engineering sequence, economic projections, and other technical conclusions should not be supplied by a witness or file organizer who lacks the necessary basis.

  • Question requiring technical knowledge and the discipline that addresses it
  • Materials provided, materials not provided, assumptions, method, measurements, calculations, limitations, and date of opinion
  • Whether the opinion addresses possibility, probability, causation, standard of care, amount, future condition, or another distinct issue
  • Any conflicting opinion and whether the reviewers relied on the same facts and time period

Keep the map auditable

  • Exact source link or file location rather than a copied conclusion without context
  • Author, review date, version, correction history, and reason for any status change
  • A separate unresolved list so missing proof is visible instead of filled with assumption
  • No deletion of an unfavorable source merely because another source appears more helpful

The related guide to testing an injury claim against competing explanations uses the completed source map to compare plausible accounts. This page owns the earlier task of identifying who or what can establish each fact.

Rosensteel Fleishman Car Accident & Injury Lawyers provides information about North Carolina personal-injury claims. A proof-source map can reveal missing foundation, but admissibility and legal significance remain matter-specific questions.

Sources