I repped her on a case w an accident that happened 3 mos before this one.

In this accident, she goes to ER, complains about her wrist and hand, admits that she'd been having trouble w it for a few weeks now.

Does PT, and the bulk of the treatment is for wrist surgery--carpal tunnel release. She's out of work for about three weeks as a housepainter w a sling on her arm, so that's a couple grand in lost wages. So, specials of about $60K. Property damage is present but nothing to get excited about. Re the most expensive component of her treatment, it's a surgery for a condition she admitted was present before the accident. Prior accident w injuries from three mos before. What's it worth?

(http://www.autoadmit.com/thread.php?thread_id=3948128&forum_id=2#35831849)

If CSLG: 800k

(http://www.autoadmit.com/thread.php?thread_id=3948128&forum_id=2#35831860)

And arent you faggots always posting ridiculous home values for digs in Cali?

If I tried that case w the venue's jury I could get $25K.

(http://www.autoadmit.com/thread.php?thread_id=3948128&forum_id=2#35831962)

I don't know your jurisdiction, but they seem more conservative. So 122K seems like a pretty decent result.

(http://www.autoadmit.com/thread.php?thread_id=3948128&forum_id=2#35831959)

Kenny has defended at least 6-8 of my depos and Chandler has defended a couple too. They will tell you that my clients perform very well for the most part.

(http://www.autoadmit.com/thread.php?thread_id=3948128&forum_id=2#35831992)

But typically its usually just trying to keep client from fucking up too much in depo that is the primarily objective. It's a "do no harm" thing which if they pass the case value goes up a bit.

I prep mine too. I spend more time w them pre depo than anyone here. I do a video, and then I meet with them for like an hour and a half. We go over their whole Chron, so they don't fuck up their past medical history, which is a killer around here. (they will all say in depo under oath they never had prior back problems unless and until you show them prior records from five years before the accident where they were in fact complaining. so you have to get them to be able to answer properly when asked about prior problems.)

I also work with them on how the accident has affected them, what things they couldn't do. we talk in prep about =holidays that occurred during the time of their treatment, and how their routines varied. I don't hit it super hard in depo because I want to hold back that stuff for trial, ftmp, although, I will say here that in med mal cases ive been hitting the damages hard in deposition --even asking them during defense counsel's depo to elaborate on how the incident affected them, and I tell them to take their time--which is technically not rules according to hoyle when my guy is their witness but I want those defense fuckers to KNOW i'm building up damages like a mother fucker for trial.

PARTY Depos here are the same as testifying in court-- defense counsel could literally read in the deposition in front of a jury in his own case in chief, and the usual evidentiary trick about being stuck w the testimony of the witnesses you call doesn't apply in that regard.

I also go over every point that will come up in my depo prep. CLs still fuck up about 20 percent of it at best. so if they get thru depo without blocking case value or freezing it, I consider that a net positive. Most of the time, they are not super impressive as witnesses notwithstanding and I only get a couple thousand more thrown on the case offer at that time. It's just the way it is.

(http://www.autoadmit.com/thread.php?thread_id=3948128&forum_id=2#35832001)

When they practice answer tell me, "I didn't even see the car coming!" I love going, "BAM!! You LOSE!! Case OVER!" and they go what what why? and I explain how that's just fucking contrib because you have to look out all the time they usually seem to get it. I practice that a lot with them. My people are always good on that. Believe me. I'll make 'em good. Shut that door, for me, will ya.

(http://www.autoadmit.com/thread.php?thread_id=3948128&forum_id=2#35832131)

I guess I try to make it personally worthwhile because I try to really get to know them during this time. We talk a bout their family, hobbies, hopes, history, all that stuff. They end up liking me a lot and knowing me and trusting me.

(http://www.autoadmit.com/thread.php?thread_id=3948128&forum_id=2#35832174)

I want to know how client is going to fuck up--and how client is going to think--I want to know how client can be manipulated into settlement. I find this a helpful way to engage in my work

(http://www.autoadmit.com/thread.php?thread_id=3948128&forum_id=2#35832472)