Visualize Your Case
County Vehicle Crash Starts with Low 5-Figure Offer and Ends with $1.57M Award

When doing the right thing leads to a devastating outcome, it’s exceptionally unjust. That’s what happened to a woman who stopped at an intersection to allow a bicyclist to cross when a Sacramento Housing and Redevelopment Agency (SHRA) employee driving a utility van approached the intersection behind her. The driver failed to stop, colliding with the rear of the woman’s vehicle, causing it to travel through the intersection and around the corner.

Initially, the woman’s injuries seemed relatively minor. She initially only complained about her knee, which had swelled and caused some difficulty walking. However, as time progressed, it became clear she suffered significant trauma to her neck – later determined to be cervical myelopathy – which further affected her ability to walk and caused numbness throughout her body. A lover of the outdoors who worked on several craft projects, these injuries prevented the woman from engaging in the day-to-day activities she previously enjoyed.

After the collision, the Defendants stonewalled the woman, refusing even to compensate her for the repairs to her car. So, she approached the law firm of Kershaw Talley Barlow for representation. Attorneys Ian Barlow and Jeffrey Schaff (now with Schaff Law Group) handled a challenging case with many obstacles. Their Plaintiff was remarkably stoic. She did not like to show her suffering and was averse to invasive treatments, so building a surgery case around someone who didn’t want to see a surgeon was difficult. The woman also suffered from Ehlers-Danlos syndrome, a genetic disorder that affects a person’s connective tissues.

Another challenging feature of this case was that the surgery hadn’t happened yet, which had the potential to make it difficult to express the seriousness of the Plaintiff’s trauma to a jury. To combat this, Ian and Jeffrey enlisted the help of several experts. They brought on her treating physician, who was adamant that she needed surgery, along with Dr. Selena Ellis, a neurologist, and Dr. Andrew Fox, a neurosurgeon.

Hearing how strongly the treating physician and experts advocated for surgery convinced Ian and Jeffrey that this case needed to go to trial to get full and fair compensation for their client. Additionally, they knew that without visuals, the jury could easily dismiss the impact of her injury and the need for future surgery. As a result, they contacted DK Global for assistance. The collaboration began with the attorneys providing the DK Global team with the treating physician’s deposition to help lay the foundation for the visuals and then involving their expert neurosurgeon to help create a roadmap for the project.

Since the woman had yet to have the surgery, it was critical that the visuals communicated to the jury the significance of what she would undergo. The animation that DK Global produced depicted, with startling clarity, the complexity and invasiveness of the surgery. Beginning with a scalpel incision to open the woman’s throat, the animation took the jury inside the cervical discectomy surgery. It showed the removal of bone and tissue, the insertion of replacement disc devices, and the fusing of the vertebrae using metal plates and screws. By taking the abstract description of such a complex procedure and bringing it into focus with animated visuals, the jury better understood the gravity of the Plaintiff’s condition.

The trial was the culmination of 4 years of work, including attempts at mediation. Early on, the Defense didn’t take the case seriously. Their initial offer was only around $20K. Dr. Fox used DK Global’s animation during his expert deposition, which helped illustrate the realities of the case. The Defense responded by raising their offer to six figures. However, they still insisted that the Plaintiff’s condition was degenerative and that she needed the surgery regardless of the collision. Ultimately, Ian and Jeffrey’s tenacity led to the courtroom. After a 9-day trial, the jury returned a verdict in favor of the Plaintiff for $1.57 million – including over $800K for future pain and suffering – bringing the case to a just conclusion.

Ian Barlow is a partner at Kershaw Talley Barlow, who focuses primarily on complex litigation in both state and federal courts. He handles cases involving consumer class actions, wage and hour claims, product liability, mass torts, fraud, and whistleblower claims, among other practice areas. Ian was recognized as a Northern California Super Lawyers Rising Star, the Best of the Bar in the Sacramento Business Journal, a Top Lawyer in Sacramento Magazine, and is rated AV-Preeminent by Martindale Hubbell. Barlow has proven that his dedication to his clients and hard work translate to outstanding results, even in highly complicated actions against large multinational corporations.

Jeffrey Schaff is a trial lawyer and principal attorney at Schaff Law Group, which primarily handles personal injury, civil litigation, and some criminal defense. He has litigated countless personal injury matters from start to finish, taken hundreds of depositions, and has tried multiple cases to verdict as lead counsel. Schaff understands that every case is as unique as the clients he represents and that they deserve attention, compassion, and zealous advocacy from their lawyer.

"You can talk about the injuries all you want, but there's nothing like having a video or an animation depict that before a jury."
Ian Barlow - Kershaw Talley Barlow
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