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, his truck hydroplaned and jackknifed across all four highway lanes. Not far behind, a mother and daughter were returning from Arizona, the daughter on her way to take the California bar exam. The truck slowly came into view in the pair’s headlights. Adrenaline coursed through their veins as they realized there was no way to veer around the jackknifed semi. The mother slammed the brakes in a futile attempt to avoid a collision. 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 truck. They were rushed to a nearby hospital. Both women sustained traumatic brain injuries and deep lacerations. Radiologists identified 15 separate fractures in the mother’s skull alone. Unfortunately, the mother’s condition worsened upon arrival, requiring numerous surgeries.
After almost a month in the hospital, the daughter was discharged. Upon referral, she sought the help of Evan Garcia and Greyson Goody of The Simon Law Group to pursue justice for her family’s pain and suffering.
Evan and Greyson reviewed the photographs and evidence from the scene. The glass on the street and blood in the car’s interior laid bare the gravity of the damages and loss the women suffered. During discovery, the pair filed 33 motions to compel. They learned that the Defendant was self-insured with a $1,000,000 policy limit. Nevertheless, the Defense contested liability throughout litigation. However, the duo uncovered dashcam footage of the Defendant driving erratically down the freeway. With liability confirmed, Evan and Greyson wanted a way to visually convey their arguments 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 four litigation visuals depicting the mother’s damages.
The first animation started with a 3D representation of the mother’s gruesome lacerations extending across her left cheek and forehead. Her skull fractures were then revealed alongside radiology scans. Medical illustrations showed CT scans superimposed over the mother’s 3D character model to accurately display the location of her traumatic brain injury.
The next animation depicted the placement of an external ventricular drain to help alleviate the mother’s traumatic brain injury. A surgical drill bored a hole through the mother’s skull. Doctors inserted a catheter, allowing excess cerebrospinal fluid to drain and alleviate pressure.
Subsequently, the third animation covered the mother’s surgery to patch the hole and prevent further cerebrospinal fluid leaks. Surgeons once again cut through the mother’s scalp, uncovering the leaking opening in her skull. A gel pack was inserted into the gap and secured with a five-point burr hole cover.
Finally, the last surgical animation recreated how surgeons mended the woman’s face. First, the surgical team sutured the mother’s cheek and forehead lacerations, and cut away necrotic tissue. Then, they peeled a portion of the mother’s face. Incisions were made underneath her eyelids and upper lip to remove embedded glass. Then, ten metal plates were screwed into the front of the mother’s skull to secure her facial fractures.
Evan and Greyson presented the animation while deposing 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 consistently been selected as a Super Lawyers Rising Star since 2018.
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.
