1. HELMS & GREENE, LLC Introduction Kirk Willis MEMBER HELMS & GREENE, LLC When it’s all on the line Adjusting Automobile accidents from the simple to the catostrophic

2. HELMS & GREENE, LLC Sanford & Son Hypothetical #1

3. HELMS & GREENE, LLC Hypothetical #2 Chico and the Man

4. HELMS & GREENE, LLC Amos & Andy Best of Friends! New Hypothetical #3

5. HELMS & GREENE, LLC Amos & Andy Best of Friends! New Hypothetical #3

6. HELMS & GREENE, LLC Property Loss Plaintiff may testify to value Mechanic, adjuster, or expert

7. HELMS & GREENE, LLC Economic Damages Medical Care Loss of Earning Capacity Property Loss

8. HELMS & GREENE, LLC Medical Care Reasonable and Necessary Past and Future Expert Testimony Needed Demonstrative Evidence Accepted

9. HELMS & GREENE, LLC Loss of Earning Capacity Recovery for Impaired Ability to Earn Testimony by a Physician Testimony by Employer PROOF

10. HELMS & GREENE, LLC Household Services The performance of household and domestic duties by a spouse.

11. HELMS & GREENE, LLC “Soft” Damages Physical Pain and Suffering Past Future

12. HELMS & GREENE, LLC Closed Head Injuries Physical Damages Psychological Damages

13. HELMS & GREENE, LLC Trial Evidence Family Members and Friends Co-Workers Expert Testimony

14. HELMS & GREENE, LLC

15. 1. Physical Appearance 2. Due to Wrongful Act Disfigurement Elements

16. HELMS & GREENE, LLC 1. Embarrassment 2. Self Consciousness Recovery PROOF 3. Loss of Intellectual Ability 4. No Need to Show Economic Loss No Longer Life of the Party Never Dances Anymore Testimony of Family:

17. HELMS & GREENE, LLC Loss of Consortium Affection Comfort Guidance Assistance Emotional Support Things Needed to Make Successful Marriage Children Take Too

18. HELMS & GREENE, LLC Not Yet Recognized in Texas Loss of Family Relations

19. HELMS & GREENE, LLC Loss of Enjoyment of Life Reasonable to Think About Courts not Addressed Too Vague

20. HELMS & GREENE, LLC Joke Break

21. HELMS & GREENE, LLC Survivor Action Heirs Appointed Legal Representative Estates Executor of Will

22. HELMS & GREENE, LLC Survivor Action Damages Pain, suffering and mental anguish Medical expenses Funeral and burial expenses Property damages Exemplary damages

23. HELMS & GREENE, LLC Bystander Claim Elements 3 rd party must have suffered serious injury or death The mental anguish suffered by the bystander must be foreseeable as determined by three factors: Bystander located near scene The shock to bystander resulted from serious and contemporaneous observation of accident Bystander must be closely related to victim

24. HELMS & GREENE, LLC Bystander Claims “Dillion” Rule “Zone of Danger” “Contemporaneous Perception” “Close Relationship Requirement”

25. HELMS & GREENE, LLC Where the plaintiff and victim were closely related Plaintiff was near scene of accident Contemporaneous perception Bystander Claims

26. HELMS & GREENE, LLC Wrongful Parties Surviving Spouse Children Parents

27. HELMS & GREENE, LLC Parents Natural? Adopted? Stepparents? Foster Parents? Managing Conservator?

28. HELMS & GREENE, LLC Children Minors and Adoptees Illegitimate Children Adult Children

29. HELMS & GREENE, LLC Exemplary Damages Limits to Recovery Spouse “Heirs of the Body” Parents Do Not Take

30. HELMS & GREENE, LLC Defenses Legal Shoes Parental Immunity Statute of Limitations

31. HELMS & GREENE, LLC Pecuniary Loss Care Maintenance Support Service Advice Counsel

32. HELMS & GREENE, LLC Loss of Companionship and Society Relationship Living Arrangement Absence Harmony of Family Common Interest

33. HELMS & GREENE, LLC Loss of Inheritance Beneficiaries may recover the present value that the deceased would have added to the estate Apartments Stocks Profit Sharing

34. HELMS & GREENE, LLC Mental Anguish Emotional Pain Torment Anguish Rather than Physical Pain

35. HELMS & GREENE, LLC Jury Consideration Relationship between parties Living arrangement Any absence for long period of time Harmony of family unit Common interests and activities Letters Photos Videotapes Audiotapes Movies

36. HELMS & GREENE, LLC Evidence Needed to Carry Burden No speculation No Passion, Bias or Prejudice

37. HELMS & GREENE, LLC 469-893-1870 kwillis@helmsgreene.com When it’s all on the line Thank You Kirk Willis Partner