What does an opening statement sound like in a Social Security disability case? In this video, I present to you an example of an opening statement very similar to one that I presented to a judge in a recent hearing.
Clear and compelling opening statements are even more important in SSDI and SSI claims in 2017 and beyond because judges are overworked and often not able to find the time to read every page of every medical report in your file. I do read every word and I use my opening statements to provide the judge a concise summary of my client’s claim.
You will notice in this opening statement example that I reference specific medical records by page number and I explain the progression of my client’s medical issues over time. I also focus on my client’s long work history and, in this particular case, her struggles to try to return to work.
In addition to preparing an opening statement, I also prepare a direct examination of my client and a cross examination of the vocational witness. I also summarize my client’s medical record into a 2 page “hearing worksheet” that I use for quick reference to specific medical exhibits.