SUCHOCKI & ASSOCIATES, P. C SOUTHWEST BLVD SUITE 222 FORT WORTH, TEXAS (817) (817)

Introduction Qualifications Board Certification in Personal Injury Trial Law Experience Litigation Management Mini-Focus Group Cost Management Reporting Outline Outline Next

Introduction Introduction Twenty Four years experience handling civil litigation in Northeast Texas: Trial experience in a wide range of civil litigation Board certification in Personal Injury Trial Law Appellate experience in civil litigation Mini-Focus Group Risk Analysis Cost Management Comprehensive Reporting Next

Experience Experience Nursing home negligence Medical malpractice Wrongful death Service station gasoline fire Residential fires Oil field explosion Tractor trailer accidents Automobile accidents Motorcycle accidents Railroad crossing accident Slip & falls Trip & falls Elevator malfunctions False arrest, slander Molestation Security violations Trespass, conversion Products liability Hardware disease Deceptive Trade Practices Insurance bad faith Uninsured/underinsured motorist Business fraud Breach of contract Breach of lease Breach of fiduciary duty Construction accidents Sexual assault Dram-Shop Tried Lawsuit involving: Next

Experience Experience Defective Software Toxic Torts Life Insurance Health Insurance Real Estate Employee/Employer Liability Non-Subscriber Liability In addition, experience handling cases involving: Next

Experience Experience Appellate Cases: Next In Re Donna Pack, et al., 996 S.W.2d 4 (Tex.App. – Fort Worth 1999)(orig. proceeding) [TDHS records/investigators not subject to medical peer review privilege]. Davis & King v. Bryant, No CV (Tex.App. – Fort Worth 1999)(not designated for publication) [Judgment affirmed – rear-end collision] Hurley v. Markum, No CV (Tex.App.- Fort Worth 1998, pet. denied)(not designated for publication) [Judgment reversed and rendered – premises liability] Nassar v. Mutual of New York, et al., No CV (Tex.App.- Houston [1st Dist.] 1998, pet. denied) not designated for publication) [Judgment affirmed – personal injury on elevator Chapman v. Ford, No CV (Tex.App.- Dallas 1998)(not designated for publication) [JNOV reversed and verdict reinstated – rear-end collision] Allied Erectors Corporation v. Barbaras Bakery, 954 S.W.2d 197 (Tex.App.- Waco 1997, no writ) [Appeal of order denying special appearance timely perfected] Butler, et al. v. Meridian Oil, No CV (Tex.App.- Fort Worth 1994)(not designated for publication) [Summary judgment affirmed – wrongful death] Deaver, et al v. Dairy Commodities, No CV (Tex.App.- Fort Worth 1993) (not designated for publication) [Judgment affirmed – contaminated cattle fee

Qualifications Qualifications Board certification in personal injury trial law Over 100 actual trials Engineering background with NASA See detailed resume See detailed resume Special knowledge in accident reconstruction case Special knowledge in software development What is a Personal Injury Trial Law Certified Attorney? Next

Counties where we have tried cases Next

Counties where we have handled cases Next

Litigation Management Litigation Management is a comprehensive management tool and a courtesy that we offer to our clients: It provides management with total visibility It categorizes cases in terms of degree of risk (liability and damages) It conducts discovery & investigation consistent with risks It recommends dispositions consistent with risks Litigation Management ensures attorney accountability and provides a forum for discussion Litigation Management provides a vehicle for controlling costs For more detail see Litigation ManagementLitigation Management Next

Mini Focus Group Mini-Focus Group is a practical tool that we have made part of our routine defense arsenal to assess risk and prepare for trial It utilizes candidate jurors to explore how they think and react to case issues It explores jury biases and common life experiences and how they affect case issues It allows the defense to construct a trial story that fits juror thought patterns For more detail, see Mini Focus GroupMini Focus Group Next

Cost Management Cost Management We have a rational methodology for controlling costs that is an integral part of litigation strategy. The elements are Date Unit Method Control Production Interrogatories Admissions Authorization Subpoena Online to Court Cases Internet PublicData Investigator Non-Stenographic Video Negotiate Rates Establish Budget Set criteria for feedback Interview Watchdog Background Records Discovery of facts Experts Next

Cost Management A Data Unit represents a typical input of relevant information A Method represents a way to obtain the Data Unit Cost management begins with an analytical choice of the Method Examples: Deposition v. Witness Interview Video v. Oral Deposition Subpoena v. Medical Authorization/Freedom of Information Act Control represents the tasks utilized in maintaining cost efficiency by price negotiations, discovery agreements, implementing budgets, imposing spending limits, monitoring invoices and implementing advanced technology Next

Cost Management Cost Management Production Interrogatories Admissions Authorization for Medical Authorization for Other records Freedom of Information Subpoena Surveillance Online to Court Cases Internet PublicData Investigator Deposition Witness Interviews Video Negotiate Prices Establish Budgets Letters of understanding Set limits for expenses Interview witnesses Examine each invoice Ask for price reductions Use digital photography Exchange discovery in pdf format via CD Consider non-stenographic deposition Discovery agreements Share records costs Share deposition costs Litigation Tasks Method Management Background Criminal Legal Pre-exiting injuries Records Medical Income Tax Returns Personnel Information Previous lawsuits Discovery of relevant facts Experts Next

Production Interrogatories Admissions Authorization for Medical Authorization for Other records Freedom of Information Subpoena Surveillance Online to Court Cases Internet PublicData Investigator Deposition Oral Non-Stenographic Witness Interviews Telephone In Person Premise Negotiate Prices Establish Budgets Letters of understanding Set limits for expenses Examine each invoice Ask for price reductions Use digital photography Exchange discovery in pdf format via CD Consider non-stenographic deposition Discovery agreements Share records costs Share deposition costs Data Unit Method Control Background Criminal Legal Pre-existing injuries Records Medical Income Tax Returns Personnel Information Previous lawsuits Discovery of relevant facts Experts Legal Research Cost Management Consider the most efficient and cost saving approach Next

Reporting is done according to client requirements Reporting available over a wide spectrum Reporting Reporting Summaries Sent by mail Sent by Client access to entire file Client can view any portion of file Client can download all of the file Next Reporting is concise and direct and enhanced with visual aids, including photographs, graphs, drawings and medical definitions to facilitate communication

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