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Draft of closing argument done

...
chest-beating stubborn indian lodge famous landscape painting
  12/10/18
good luck
frum address striped hyena
  12/10/18
I’m just hoping to get my costs back. Gonna ask for a...
chest-beating stubborn indian lodge famous landscape painting
  12/10/18
180 break a leg
wild angry prole
  12/10/18
POAST IT. you might actually get good advice.
Canary business firm
  12/10/18
Don’t think xo gives good advice on this stuff. I bas...
chest-beating stubborn indian lodge famous landscape painting
  12/10/18
how much are you asking for how much comp how much puniti...
brilliant adventurous theater
  12/10/18
No punitives, it’s a rear ender. Asking for $49,200 ...
chest-beating stubborn indian lodge famous landscape painting
  12/10/18
is the last argument permissible?
Canary business firm
  12/10/18
Why would it not be?
chest-beating stubborn indian lodge famous landscape painting
  12/10/18
seems golden-rule-ish
Canary business firm
  12/10/18
If it’s barred I’ll switch to $19 dollars a day....
chest-beating stubborn indian lodge famous landscape painting
  12/10/18
that sounds like it could be mistrial territory
frum address striped hyena
  12/10/18
do shitlaw judges declare mistrials and have to hear the sam...
Canary business firm
  12/10/18
in criminal, it happens, albeit rarely (and it pisses off ev...
frum address striped hyena
  12/10/18
Criminal is different. No prosecutorial misconduct, no due p...
Canary business firm
  12/10/18
Why? Closing arguments you have huge latitude. Basically t...
chest-beating stubborn indian lodge famous landscape painting
  12/10/18
will there already be testimony of the defendants expert rat...
brilliant adventurous theater
  12/10/18
I’m going to cross examine the doctor on that tomorrow...
chest-beating stubborn indian lodge famous landscape painting
  12/10/18
A per diem argument can be based on an expert's fee? Seems i...
Canary business firm
  12/10/18
why not? you can say our compensatory request is just 2 hour...
brilliant adventurous theater
  12/10/18
You can argue based on a company's profits? That seems unfai...
Canary business firm
  12/10/18
What is the rule about mentioning insurance?
Fuchsia university gunner
  12/10/18
if the jury is convinced of the injury and pain then if you ...
brilliant adventurous theater
  12/10/18
Poast it anyway. You can't be bothered by insults on xo
wild angry prole
  12/10/18
This. There was nothing wrong w yr opening at all. There a...
charcoal swashbuckling codepig dog poop
  12/10/18
...
jet provocative stag film legend
  12/10/18
...
chest-beating stubborn indian lodge famous landscape painting
  12/10/18


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Date: December 10th, 2018 12:55 AM
Author: chest-beating stubborn indian lodge famous landscape painting



(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37380996)



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Date: December 10th, 2018 12:56 AM
Author: frum address striped hyena

good luck

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37380998)



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Date: December 10th, 2018 12:58 AM
Author: chest-beating stubborn indian lodge famous landscape painting

I’m just hoping to get my costs back. Gonna ask for a lot more, clients have significant permanent damage in their spine.

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381002)



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Date: December 10th, 2018 12:58 AM
Author: wild angry prole

180 break a leg

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381005)



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Date: December 10th, 2018 1:00 AM
Author: Canary business firm

POAST IT. you might actually get good advice.

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381013)



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Date: December 10th, 2018 1:23 AM
Author: chest-beating stubborn indian lodge famous landscape painting

Don’t think xo gives good advice on this stuff. I basically copied my opening from a trial attorney much more accomplished in PI than anyone here and it got insulted beyond belief. I’m just worried I’m asking for too much money and might offend the jury.

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381068)



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Date: December 10th, 2018 1:26 AM
Author: brilliant adventurous theater

how much are you asking for

how much comp how much punitive

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381074)



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Date: December 10th, 2018 1:31 AM
Author: chest-beating stubborn indian lodge famous landscape painting

No punitives, it’s a rear ender. Asking for

$49,200 in past meds (each client has over 100k in meds but my expert cut them down a lot saying they’re unreasonable)

$162,000 in future meds (lumbar fusion and extra testing)

$120,500 in past pain and suffering (100 per day)

$140,000 future pain and suffering (defense doctor charges $7000 for a half day of testimony, saying one half day of defense doctor testifying per year for the next 20 years)

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381089)



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Date: December 10th, 2018 1:34 AM
Author: Canary business firm

is the last argument permissible?

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381096)



Reply Favorite

Date: December 10th, 2018 1:35 AM
Author: chest-beating stubborn indian lodge famous landscape painting

Why would it not be?

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381100)



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Date: December 10th, 2018 1:36 AM
Author: Canary business firm

seems golden-rule-ish

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381102)



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Date: December 10th, 2018 1:38 AM
Author: chest-beating stubborn indian lodge famous landscape painting

If it’s barred I’ll switch to $19 dollars a day. But the jury will have already heard the equivalency of my request to the hour of the doctor testifying.

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381105)



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Date: December 10th, 2018 1:39 AM
Author: frum address striped hyena

that sounds like it could be mistrial territory

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381108)



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Date: December 10th, 2018 1:40 AM
Author: Canary business firm

do shitlaw judges declare mistrials and have to hear the same garbage case again?

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381110)



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Date: December 10th, 2018 1:41 AM
Author: frum address striped hyena

in criminal, it happens, albeit rarely (and it pisses off everyone)

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381112)



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Date: December 10th, 2018 1:49 AM
Author: Canary business firm

Criminal is different. No prosecutorial misconduct, no due process, etc in a shitlaw trial like in a crim trial. Wonder how many shitlaw mistrials there ever are. Has to be really rare.

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381138)



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Date: December 10th, 2018 1:42 AM
Author: chest-beating stubborn indian lodge famous landscape painting

Why? Closing arguments you have huge latitude. Basically the rule is don’t mention insurance. No golden rule.

Per diem argument is allowed in California.

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381116)



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Date: December 10th, 2018 1:46 AM
Author: brilliant adventurous theater

will there already be testimony of the defendants expert rate of 7k or will closing argument be the first time the jury hears it?

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381126)



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Date: December 10th, 2018 1:48 AM
Author: chest-beating stubborn indian lodge famous landscape painting

I’m going to cross examine the doctor on that tomorrow

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381134)



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Date: December 10th, 2018 1:51 AM
Author: Canary business firm

A per diem argument can be based on an expert's fee? Seems improper to me but I don't have a clue. Why not do it based in sucker kike's salary?

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381146)



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Date: December 10th, 2018 1:53 AM
Author: brilliant adventurous theater

why not? you can say our compensatory request is just 2 hours worth of evil company's profits. why not extend it to defense expert.

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381154)



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Date: December 10th, 2018 1:56 AM
Author: Canary business firm

You can argue based on a company's profits? That seems unfair to me and seems like a punitive damages argument. Unless we're talking about a business case where some company's profits are at issue like a royalty case, it just seems irrelevant and a plea to emotions.

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381163)



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Date: December 10th, 2018 9:45 AM
Author: Fuchsia university gunner

What is the rule about mentioning insurance?

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381847)



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Date: December 10th, 2018 1:34 AM
Author: brilliant adventurous theater

if the jury is convinced of the injury and pain then if you break it down into categories that doesn't seem all that reasonable. if you opened with we want half a mil it would seem like a lot, but explain it similar to how you did above and theyll get that there is a rational to asking for what you are

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381098)



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Date: December 10th, 2018 1:33 AM
Author: wild angry prole

Poast it anyway. You can't be bothered by insults on xo

(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381095)



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Date: December 10th, 2018 9:41 AM
Author: charcoal swashbuckling codepig dog poop

This.

There was nothing wrong w yr opening at all. There are other approaches, for other cases, but yours was very good and suited the circumstances and trial posture of your case.

Have you considered not saying “What I say isn’t evidence”?

Good luck!



(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381839)



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Date: December 10th, 2018 1:22 AM
Author: jet provocative stag film legend



(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381065)



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Date: December 10th, 2018 9:24 AM
Author: chest-beating stubborn indian lodge famous landscape painting



(http://www.autoadmit.com/thread.php?thread_id=4152965&forum_id=2#37381791)