Sample Closing Powerpoint This is a sample PowerPoint closing statement in an auto accident case. The jury in this case awarded over $660,000. It is a little bit of a mess because of the desire to redact pictures, names, etc. But it should give a guide as to how to use Powerpoint in a closing statement. (Best piece of advice: keep away from the bullet points and stick to the evidence.)
Buckner: Not the right doctor for the job Dr. Buckner Date of Surgery: May 31, 2006
WRONG! WRONG! What did Dr. Buckner actually do?
Who are the RSD Experts? I didn’t know she has RSD. Dr. Buckner
Buckner testified that he is not an expert in RSD • Admitted by defense counsel • We’re not offering him as an expert in RSD or pain management
I didn’t know that Ms. May has RSD Dr. Buckner
“Swelling?” Dr. Buckner
Dr. Tarantino • 2/5/08: Ms. May presents with: • Global pain, tender in many areas • Hyperesthetic: more pain than he would expect • 8/19/08: Ms. May presents with: • Patellar-femoral tenderness • Diffuse, hyperesthetic tenderness
Dr. Taber’s “Solution”: Modify Your Lifestyle; Avoid Activities that Cause Pain
Taber is not an RSD Expert • He did not contradict Dr. Munson’s conclusions.
She has a damaged patellar tendon caused by the impact She also has symptoms of RSD, so I’m sending her to Dr. Elroy Dr. Munson
Ms. May Dr. Munson Physical Therapist identified the source of pain in the patellar tendon, confirmed by Munson.
What are the Symptoms of RSD? • Swelling • Hyperesthesia (extremely sensitive to touch) • Temperature changes • Stiffness • Color changes Dr. Elroy
It is uncontradicted that Ms. May has RSD • It was caused by the impact—Ms. Vinger is responsible • No medical evidence disagrees • No doctors disagree
Ms. May clearly has RSD. She needs a spinal stimulator implant. Dr. Elroy The RSD Expert
Ms. May Ms. May Dr. Elroy
Past Medical Expenses • GBMC Emergency Room $ 338.75 • Charles Emergency Phys. $ 217.00 • Dr. Johnson $ 1,828.00 • MRI on 05/09/06 $ 1,431.00 • Dr. Munson $ 3,325.00 • Union Memorial Hospital $ 2,283.00 • Hereford PT (6/16/06 to 7/5/06) $ 1,230.00 • Dr. Elroy $ 3,160.00 • Dr. North/Sinai Hospital $35,084.52 TOTAL: $48,897.27
Lost Wages 04/17/06 to 09/04/06 • Waitressing: 5 weeks $1,225.00 average $245.00 per week • Lifeguarding: Summer $1,698.88 TOTAL: $2,923.88
Low End High End 2019 (age 31) $22,000.00 $28,000.00 2028 (age 40) $22,000.00 $28,000.00 2037 (age 49) $22,000.00 $28,000.00 2046 (age 58) $22,000.00 $28,000.00 2055 (age 67) $22,000.00 $28,000.00 2064 (age 76) $22,000.00 $28,000.00 TOTAL: $132,000.00 $168,000.00 FUTURE MEDICAL COSTS
PAST HARMS AND LOSSES • Enduring two knee surgeries • Two injections to her knee • Four epidural injections in her back • Spinal cord stimulator cord implant - trial • Spinal cord stimulator implant – permanent placement • Dealing with Doctors who could not make the appropriate diagnosis:
Current Harms & Losses • Moderate pain 20 days out of every 30 • Severe pain occassionally • 9 more surgeries required • No more sports or “active” lifestyle: avoid breaking leads in spinal stimulator implant
EMOTIONAL SUFFERING • NOT KNOWING WHY SHE WAS IN PAIN • NO HOPE IN SIGHT FOR FOUR YEARS • NOT BEING ABLE TO RETURN TO A NORMAL LIFESTYLE • PERMANENT IMPLANT • SIX MORE SURGERIES • MUST LIVE A RESTRICTED LIFESTYLE
2,928.33 48,897.27 150,000.00 356,000.00 557,825.00