Sacramento Bus Driver Injured In Auto Collision, Part 1 of 9

The following blog entry is written from a defendant’s position post-verdict. Reviewing this kind of briefing should help potential plaintiffs and clients better understand how parties in personal injury cases present such issues to the court.

(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this car accident/bus accident case and its proceedings.)

Defendants Universal Cafe and Randy Smith submit the following Memorandum of Points and Authorities in Opposition to Plaintiff’s Motion for Judgment Notwithstanding the Verdict.


Plaintiff presented claims for personal injury over the course of a six-day trial. During trial, evidence presented established that plaintiff was making exorbitant claims as a result of a minor scraping contact against the front right corner of a bus she was driving. Evidence further established that plaintiff has exaggerated and misrepresented claims and facts throughout this case. For example, the jury watched plaintiff limp in front of them with a cane for several days, and then saw videotape evidence of plaintiff walking freely and uninhibited without a cane taken just days before trial commenced. Based on all evidence, the jury returned a verdict finding that plaintiff suffered no injury. For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

Clearly frustrated at having been exposed for misrepresentation and deception, plaintiff now moves for a judgment notwithstanding the verdict, claiming that undisputed medical evidence establishes that she sustained an injury.

As discussed below, evidence at trial showed that based on the unreliable history provided, plaintiff may have sustained contusions and/or sprain/strain injuries, however, no medical evidence conclusively established such injuries. Instead, medical evidence established plaintiff’s lengthy history of exaggerated, dramatic, and inappropriate misrepresentation and deception in this case. Based on such evidence, the jury properly found that plaintiff was not injured as claimed. (See Part 2 of 9.)

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

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