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$11M Settlement Attained Using Damages Overview Animation for Woman With 15 Skull Fractures

The driver of an 18-wheeler sped down the I-10 freeway west of Palm Springs, California. It was midnight, and blinding rain slickened the road and obstructed the view out the driver’s windshield. Suddenly, he lost control, causing the truck to jackknife across the interstate. Simultaneously, a mother and daughter traveling in a passenger vehicle – their windshield wipers failing to keep up with the downpour – struggled to see the hazard ahead. They slammed on their brakes as the truck’s side markers came into view, reflecting their headlights. But they had nowhere to go. The car crashed underneath the trailer, nearly shearing its roof off completely.

First responders worked quickly to free the women using the jaws of life. They were rushed to a nearby hospital. Both women sustained catastrophic injuries, including large lacerations and traumatic brain injuries. However, radiologists also identified 15 separate fractures in the mother’s face, requiring several intensive surgeries.

A few weeks later, the daughter was released from the hospital. Searching for an attorney, she was referred to Evan Garcia and Greyson Goody of The Simon Law Group. The two reviewed photographs of the collision; blood and glass coated the car’s interior. They acted quickly and fervently to organize their evidence, filing 33 motions to compel during discovery. They learned the Defendant was self-insured with a $1M policy limit.

The Defense disputed liability throughout the litigation. However, a witness Evan and Greyson deposed shared dashcam footage of the Defendant recklessly charging down the highway. With liability clear and trial in their sights, Evan and Greyson shared their clients’ medical records with DK Global to create a series of litigation visuals to show the mother’s damages. They planned to use the demonstratives throughout the litigation, beginning with the deposition of their medical experts, extending through mediation and into trial if it went that far.

The first animation commenced with a 3D model of the woman’s grisly lacerations extending across her left cheek and forehead. Her skull was revealed alongside medical scans to unveil her overwhelming number of fractures. Medical illustrations showed the woman’s CT scans superimposed over her 3D model to identify the location and severity of her traumatic brain injury. Next, two of the woman’s surgeries were reconstructed, demonstrating how doctors drilled into her skull to drain excess cerebrospinal fluid surrounding her brain. Finally, a surgical animation recreated how physicians mended the woman’s broken face. Before repairing the massive number of facial fractures, surgeons sutured her lacerations and removed necrotic tissue. Then, they peeled a portion of the woman’s face from her skull to secure the fractures with metal plates. Viewers could easily infer what the road to recovery afterward looked like.

Evan and Greyson played the animation during a deposition of their client’s treating surgeon, who was happy to help his patient attain justice. The surgeon was amazed at the accuracy of the depictions. After realizing the impact the animation would have on a jury trial, the Defense became eager to settle the case. Evan and Greyson’s determination paid off: they attained $11M for their clients, eleven times the Defendant’s policy limit.

Litigation Manager and trial attorney Evan Garcia has recovered over $30 million in verdicts and settlements, representing survivors of catastrophic injuries in California and Texas. Before joining The Simon Law Group, Evan worked at a boutique law firm and consulting agency as the youngest member to supervise a team of tax controversy professionals. Additionally, Evan serves as a liaison to Justice HQ, a members-only plaintiff’s organization of high-caliber attorneys.

Greyson Goody is a Partner and senior trial attorney at The Simon Law Group. Since beginning his career, Greyson has obtained over $40 million in jury verdicts. In 2019, Greyson was named “Street Fighter of the Year” by the Consumer Attorneys of California and has been consecutively recognized as a “Rising Star” by Super Lawyers since 2018.

"You know they get scared in depositions when they start objecting to foundation... because they're trying their best to exclude them at trial, because they're so damaging for the defense."
Greyson M. Goody – The Simon Law Group
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