Late one stormy night near Palm Springs, California, heavy rain pounded the I-10 freeway, creating slick and treacherous conditions. Despite the danger, a big rig driver pushed through the traffic, struggling to see through the battering water on his windshield. Suddenly, the truck hydroplaned and jackknifed across all four highway lanes. Not far behind, a mother and daughter were returning from Arizona. With the daughter on her way to take the California bar exam. While the pair drove down the same road, they encountered the barrier the truck had created. Adrenaline coursed through their veins. And the mother slammed the brakes to avoid a collision.
As the mother and daughter tried to break, their reactive adrenaline quickly turned to fear. In the fragment of a moment, they realized that the rain had decreased the tension between the brakes and the asphalt, and they were about to crash into the side of a fully loaded 18-wheeler. The impact was so strong that it underran the semi-truck bed. As a result, the sedan’s roof was almost completely torn off, wedging the occupants underneath.
It took an entire squad of firefighters to free the women from underneath the semi-truck. They were rushed to a nearby hospital. Both women had sustained traumatic brain injuries and multiple lacerations. Radiologists identified 15 separate fractures in the mother’s skull alone. Unfortunately, the mother’s condition worsened upon arrival, requiring her to undergo numerous surgeries. Finally, after almost an entire month in the hospital, the daughter was discharged. And upon referral, she sought the help of Evan Garcia and Greyson Goody of The Simon Law Group to pursue justice for the pain and suffering her family had endured.
Evan and Greyson reviewed the photographs and evidence from the scene. From the glass on the street and blood in the car’s interior, they understood the gravity of the damages and loss the women suffered. During discovery, the pair filed 33 motions to compel. Learning the Defendant was self-insured with a $1,000,000 policy limit. With the Defense opposing liability throughout litigation, the duo uncovered dashcam footage of the Defendant driving erratically down the freeway. With liability confirmed, Evan and Greyson wanted a way to visualize this case to take control of the depositions and prepare for trial. The pair shared their clients’ medical records with DK Global to create a series of litigation visuals to show the mother’s damages.
The initial animation started with a 3D representation of the mother’s gruesome lacerations extending across her left cheek and forehead. Her skull was then revealed alongside the Radiology scans to display her fractures. Medical illustrations showed the CT scans superimposed over the mother’s 3D model to display the location of her traumatic brain injury accurately. Next, the surgery to drain the cerebrospinal fluid leak under her parietal bone was animated, showing where surgeons patched the brain hemorrhage. Finally, a surgical animation recreated how surgeons mended the woman’s face. Prior to repairing the significant amount of facial fractures, the surgical team sutured the lacerations and removed any necrotic tissue. Then, they peeled a portion of the woman’s face from her skull to secure the fractures with metal plates. Providing an easy understanding to the viewers of what the road to recovery would look like.
Evan and Greyson presented the animation during a deposition of their client’s treating surgeon. The surgeon was impressed with its remarkable precision. Recognizing the potential impact the animation could have in a jury trial, the Defense quickly sought to settle the case. The pair’s diligent efforts ultimately paid off, resulting in an $11,000,000 settlement for their clients — eleven times the Defendant’s policy limit.
Greyson Goody has been a partner and senior trial attorney at The Simon Law Group for over ten years. Since becoming an attorney, Greyson has obtained over $40,000,000 in jury verdicts and has received multiple awards for his work, including the Street Fighter of the Year award from CAOC in 2019. In addition, Greyson has been selected as a Rising Star attorney from 2018-2023 by Super Lawyers.
Evan Garcia is a litigation manager and trial attorney at The Simon Law Group. His practice focuses on all types of catastrophic injury cases. As a Plaintiff’s attorney, Evan has helped recover over $30,000,000 in verdicts and settlements. Evan holds licenses in both California and Texas.
