Sample Closing Powerpoint This is a sample PowerPoint closing

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

! G N O R W ! G N O R W 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 Dr. Munson 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? Dr. Elroy Swelling Hyperesthesia (extremely sensitive to touch) Temperature changes Stiffness Color changes

May 11, 2006 Continues to have popping and catching of the knee (Buchalter) Jun 8, 2006 Pain in left leg and calf; swelling in calf Went to ER to rule out blood clots (GBMC) Apr 27, 2006 Aug 24, 2006 Globally tender; out of proportion (Buchalter) Therapy helped initially, but became problematic (Buchalter) Apr 24, 2006 Swelling & pain in entire leg, tingling sensation (Bucci) May 31, 2007 Apr 17, 2006 Reports that knee gives out about three times a week (Buchalter) Pain throughout the leg from the hip down to the ankle (GBMC) Apr 2006 Apr 17, 2006 Ms. Wingerhits hitsPlaintiff Ms. Moore Defendant Jul 2006 Oct 2006 Jan 2007 Apr 2007 Jul 2007 Oct 2007 J

Feb 5, 2008 Jul 15, 2009 Global pain; hyperesthetic never back to normal since impact (Tarantino) Jan 2008 Increased swelling, stiffness, color change (Matthews) Aug 3, 2009 Swelling, stiffness, color changes, increased sensitivity, change in temperature; pain around leg, knee and foot (Elsamanoudi) Aug 19, 2008 Pain out of proportion, diffuse pain, patellarfemoral tenderness (Tarantino) Sep 24, 2009 Pain in entire leg up to hip (Elsamanoudi) Jul 15, 2009 Increasing pain, more swelling, redness, discoloration (Matthews) Nov 16, 2009 Temperature changes (Elsamanoudi) Apr 2008 Jul 2008 Oct 2008 Jan 2009 Apr 2009 Jul 2009 Oct 2009

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

Dr. Elroy The RSD Expert Ms. May clearly has RSD. She needs a spinal stimulator implant.

Dr. Elroy

Dr. Elroy

Ms. May Ms. May Dr. Elroy

Past Medical Expenses 1. 2. 3. 4. 5. 6. 7. 8. 6. 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 average 245.00 per week Lifeguarding: Summer TOTAL: 1,225.00 1,698.88 2,923.88

FUTURE MEDICAL COSTS 2019 (age 31) 2028 (age 40) 2037 (age 49) 2046 (age 58) 2055 (age 67) 2064 (age 76) TOTAL: Low End 22,000.00 22,000.00 22,000.00 22,000.00 22,000.00 22,000.00 132,000.00 High End 28,000.00 28,000.00 28,000.00 28,000.00 28,000.00 28,000.00 168,000.00

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