Preliminary Sections

• Author: Jim Wren/Laura Brown
• Pages: 1-34

PROVING DAMAGES TO THE JURY

by Jim Wren and Laura Brown

HIGHLIGHTS

With this new edition of Proving Damages to the Jury, we are pleased to welcome a co-author: Laura

Brown, a partner in Williams & Brown. Together, author Jim Wren and Ms. Brown have updated the book

with new and expanded coverage of a broad range of substantive topics and practical advice, including:

Client Interview and Investigation

• Topics to review with your client at your initial meeting, in personal injury and wrongful

death cases.

• In a wrongful death case, how and when to approach family or close friends with a request

for photos/videos of the deceased.

Valuations and Damage Models

 -

sonal injury or wrongful death case.

Damage Experts and Daubert/Frye Issues

• Discoverability of experts’ “draft reports,” notes, outlines, memoranda and emails.

• The analysis applicable to opinions based on technical and other specialized knowledge may

Daubert, depending on whether the jurisdiction

also has adopted Kumho.

Working With Damage Experts

• How and why to research an expert’s testifying history.

• Tips for how best to provide records to your life care planner expert.

• Challenges of qualifying an expert to express an opinion on life-expectancy.

Developing Your Visual Strategy

• Putting the visual story together, so that each phase of your damages story is represented.

 

 

• How spending time with your client's family members, friends and caregivers can help you

develop the anecdotal story of your case and the visuals to support that story.

• The importance of choosing the right color scheme for your visuals.



• Pre-existing conditions.

• Loss of consortium.

• Vicarious liability.



• Use of Double-Pulsed-Field Gradient MRI (dPFG MRI).

 

testimony as reliable.

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