(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this brain injury/car accident case and its proceedings.) PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION FOR JUDGMENT NOTWITHSTANDING THE VERDICT MEMORANDUM OF POINTS & AUTHORITIES INTRODUCTION On September 9, 2005, a completely…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this brain injury/car accident case and its proceedings.) Choo froze, bringing his vehicle to a stop as it straddled the #2 lane (slow lane) on the Highway 160 westbound, directly…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this brain injury/car accident case and its proceedings.) Plaintiff offers the following Motion in Limine No. 3, regarding the following topics: Expert witnesses for the defense trying to offer and…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this brain injury/auto accident case and its proceedings.) Archie weighed approximately 125 lbs at the time of the incident and after being discharged from the hospital dropped to a mere…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this brain injury/auto accident case and its proceedings.) Here, defendant and two independent witnesses, Cathy and Frank Bennett, testified that defendant was stopped at the stop sign. Therefore, Archie, who…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this brain injury/auto accident case and its proceedings.) Several witnesses, observing that Archie was underneath the SUV screamed at defendant to stop. Defendant, completely oblivious as to what was happening,…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this brain injury/auto accident case and its proceedings.) PLAINTIFF’S TRIAL BRIEF STATEMENT OF FACTS November 28, 2003, was Sunday of Thanksgiving weekend. Plaintiff Archie Smith, a Sacramento resident, was twenty-one…
(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.) GENERAL DAMAGES As a result of his injuries Paul has experienced severe pain and suffering and emotional distress. Paul was nearly killed…
(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.) DAMAGES As discussed above, Paul Martin suffered severe personal injuries as a result of the collision. Paul suffered a severe skull fracture,…
(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.) The investigation performed by the Gas Company’s experts confirmed that the speed of Mr. Brown’s Ford F-150 was 50.7 to 60.3 miles…