It was a humid summer in Tyler, Texas. The driver of an 18-wheeler set his cruise control and barreled into a construction zone. In his path was a family vehicle with children as young as two years old in the back seat. The driver slammed on his brakes, but it was too late – he crashed into the car’s rear end, injuring all occupants. An eight-year-old girl, who sat in the back with her cousins, suffered a traumatic brain injury, a fractured skull, and a broken femur, requiring several emergency procedures. Daryl Derryberry, Craig Zips, and Guy Wade of Derryberry Zips Wade, PLLC represented the girl and her family, attaining a confidential eight-figure plus settlement against the trucking company and its driver using an animation highlighting their client’s damages and surgeries.
First responders rushed the girl to a nearby hospital. Radiologists revealed several orthopedic fractures and damage to her frontal, temporal, and occipital lobes, causing cognitive deficits and an increased risk for psychosocial dysfunction. Surgeons drilled an ender nail into her broken femur; they peeled her face back before securing an array of screws and plates to her skull. Ten days later, Daryl, Craig, and Guy were referred to help the family navigate their legal recourse and obtain justice.
The attorneys planned for trial, reviewing the family’s mass of medical records and evidence. They retained several experts, including an accident reconstructionist, a neuropsychologist, and the girl’s treating physician. Simultaneously, after reviewing information from both vehicles’ event data recorders, the Defense realized the girl was unbelted during the crash. Thus, they attempted to minimize her damages, alleging the adults were comparatively at fault for her injuries. However, with the help of their liability experts, Daryl, Craig, and Guy overcame the Defense’s claims.
Still, because of the girl’s substantial and complex injuries, the attorneys needed to illustrate how it would alter her life forever. To help reinforce their case, they brought their team of experts and DK Global together to create an animation that summarized the girl’s damages and her resulting cognitive impairments.
The animation commenced with the girl's likeness modeled in 3D; her right eye was swollen and bruised from the collision. Her skull was revealed and showed a large fracture running across her frontal bone down to her orbital roof and right cheek, causing difficulty seeing. Her medical imagery was displayed alongside each injury. Next, large metal plates and screws were bolted onto the girl’s skull, illustrating the painful and invasive surgeries she endured. The ender nail was inserted into the femoral shaft to secure her fractured leg. Finally, the girl’s MRI scans were superimposed over her 3D model, identifying the damaged regions and corresponding impairments, including memory loss, impeded intelligence, and depression.
Daryl, Craig, and Guy reinforced their demand package with the visual. Then, 60 days before trial, they reshared the animation at mediation, attaining an eight-figure plus confidential settlement for their client.
Daryl Derryberry is listed as one of the “Top-Rated Personal Injury Attorneys” in Tyler, Texas. He is board certified in personal injury trial law by the Texas Board of Legal Specialization and has been recognized as a “Super Lawyer” by Texas Monthly Magazine for four consecutive years. He is also a member of the Million Dollar Advocates Forum and is “AV Preeminent Rated” by Martindale Hubbell.
Craig Zips is board certified in personal injury trial law by the Texas Board of Legal Specialization and has earned the premiere “AV rating” by Martindale Hubbell. He has received recognition as one of the “Top 100 Personal Injury Litigators” by The National Trial Lawyers.
Guy Wade has over three decades of experience litigating complex matters in state and federal courts. Guy practices out of the firm’s Dallas, Texas office and is a member of the Texas Trial Lawyers Association, the Dallas Trial Lawyers’ Association, and the Million Dollar Advocates Forum, one of the most prestigious groups of trial lawyers in the United States.
