Prepare chronoogical resume
Draw attention to the pertinent facts of the case:  we will investigate the past medical history for relevant/ significant illnesses or medical events; look at the critical period of time during which the alleged negligence took place; review the current health and welfare of the claimant; draw all these facts together to assist an expert in deciding whether the claimants current/ resulting suffering is as a result of unrelated events in their past medical history, whether something did go wrong / the claimant has been a victim of negligent medical practise or whether the outcome is unfortunately just a recognised, inherent risk.