(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this brain injury/personal injury case and its proceedings.)
PLAINTIFF’S TRIAL BRIEF
INTRODUCTION & FACTUAL BACKGROUND
On November 2, 2005, at 11:35 a.m., 14-year-old Paul Martin was a passenger with his mother Sherrie while driving eastbound on California State Route 40 in Sacramento. The Plaintiffs made a lawful left turn at White Road where they were violently struck by a California Gas Company truck driven by Dan Brown which ran through a solid red light. Paul Martin suffered life threatening injuries including a severe traumatic brain injury that has permanently disabled him.
Paul Martin was an active fourteen-year-old boy at the time of the collision. He was in the eighth grade at Sacramento Junior High School and enjoyed riding dirt bikes, skateboarding, building and repairing bicycles, drawing, and playing basketball. Prior to the collision Paul had been a below-average student, but had recently found success with an independent studies program in which he received mostly A’s and B’s. After suffering a moderate to severe traumatic brain injury, Paul’s entire life has changed. His ability to process information, memory, ability to communicate, and motor skills are now drastically diminished. Paul’s personality has completely changed, he is depressed, lacks ambition, and he can no longer engage in many of the activities he used to enjoy. As a result of the impact of the collision, Paul has a large 6″ scar on the back of his head, a drooping left eye, and partial facial palsy.
Sherrie Martin escaped the collision with only soft-tissue injuries.
Dan Brown is an employee of the California Gas Company ( Gas Company ). Mr. Brown is employed as a field planning associate involved with coordinating contractors throughout the Central Valley area to ensure that the Gas Company lines are not damaged during construction. On the date of the incident in question Brown was en route to a work-related meeting in Sacramento. (See Part 2 of 7.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.