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Attorney Insights: Why Trial Preparation is Key in Personal Injury Cases

Video Transcript

I know I’ve said it and I can’t say it enough. Preparation, preparation, preparation. Nothing more important than that.

Preparation and handling a case. It’s one thing to walk into a courtroom and say, “Ready for trial.” It’s another thing to walk into a courtroom and really be ready for that trial. A jury of six men and women are going to determine the extent of damages that my client is entitled to.

Uh, I have to show that my client is entitled to those damages. I only do that by being prepared. Uh, it’s not enough to hear about what my client went through. I want to show this jury and this judge what my client went through.

So, if my client has had an MRI and it’s found a tear in their shoulder, a tear in their knee area, herniated disc in their back, I’m going to show that to the jury. I’m going to have a video screen up. I’m going to show them what the spine looks like. I’m going to show them what the shoulder looks like. I’m going to have an illustration done that shows them exactly what that tear looks like and what that herniated disc looks like.

If there’s a surgery, I’m not going to just talk about that surgery. I’m going to have the operative report and those photos taken during a surgery blown up and put on a screen and shown to that jury so I can explain that to them.

Uh, that’s one way to be prepared. Another way to be prepared is make sure there are no surprises. If there are witnesses on that police report, I’m going to speak to those witnesses, and then I’m going to ask those witnesses if they know of any other witnesses. Never, ever be surprised.

Uh, if I’m preparing for a trial, I want every single medical record from every doctor my client’s seen in that courtroom, ready to go into evidence.

I spoke about it a little bit earlier. If somebody falls or somebody has an accident and I don’t have a police report or I don’t have any witnesses, knock on doors, ring doorbells, speak to people.

We get it all the time. We get Ring camera videos all the time. I get store owners all the time that tell me they saw a horrific accident. Maybe didn’t see the accident, but they saw my client after the accident and they could speak to the damages and how upset and how traumatized somebody was.

And once you speak to one witness, other witnesses seem to come forward.

FOIL requests. A FOIL request is requesting records filed with a municipality. Uh, have any permits been filed, requests to do work in an area? I don’t know the day an accident occurs whether or not it’s just the owner of the property involved here or if there were three permits to three utility companies and three construction companies who also may have done work in the area and created a very dangerous condition. I have to know all of these things.

Uh, preparation, dotting your I’s, crossing your T’s. Uh, like I said, preparation, communication, nothing can be more important in our line of work.

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