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Opening Statements in an actual trial in a personal injury case in Florida

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Now, at this time, the attorneys are going to give their opening statement. Let me advise you, opening statement is not evidence; it’s what the attorneys feel the evidence will show in the case, and we’ll start with the plaintiff. Thank you, Your Honor. May it please the Court? You may begin. Counsel. Good morning ladies and gentlemen of the jury. The first safety rule for backing your car is that a driver is required to look behind him when backing his car to prevent colliding into another car or person who may be behind them to protect them from being hit. And if they do not and as a result hurt someone, the driver is responsible for the harm. Now, let me tell you what happened in this case.

Opening Statements in an actual trial in a personal injury case in Florida
Opening Statements in an actual trial in a personal injury case in Florida

On June 6th, 2007, Dr. Baptiste was driving his car in a parking lot. He exited the parking lot that’s designed for a right turn only. Dr. Baptiste turned his car towards the left instead of the right. His left driver’s tire went up onto a raised concrete median. It’s sort of shaped like a triangle. Then his right tire went up onto the raised concrete median. Then both tires went over the median and crossed the concrete median, and his vehicle was straddling the concrete median. Mr. Baptiste applies his brakes, and he stops his car. Mr. Baptiste moves his hand from the steering wheel to the gear shifter. Mr. Baptiste’s car is a front wheel drive vehicle. Mr. Baptiste shifts the car into reverse; he moves his foot from the brake to the accelerator.

Mr. Baptiste gives his car gas, and it rocks backwards. Mr. Baptiste lets off the gas. He gives his car more gas and revs his engine. This time the car does not come off the median. He lets his foot off the gas, and then he puts his foot back on the gas one more time, and he begins to back up, and he accelerates really hard, and the front wheels come off the top of the median, and he begins accelerating backwards. And then Dr. Baptiste’s car comes off the median. Dr. Baptiste’s car is traveling backwards, and it hits the car that was stopped behind him trying to make a right turn to exit the parking lot. We’re suing Mr. Baptiste for two reasons. The first is he violated the safety rule about backing up his car, and when he backed up his car, he did so so fast with enough speed that it caused an aggravation of a surgery and caused new injuries to Dannette Griffith for which the defendant has denied any consequences.

The witnesses I expect you to hear from are her treating doctors: Dr. Ramond Priewe, Dr. Brian James, and Dr. Shugart. Before we came to trial, a few things had to be determined. So I asked Dr. James and Dr. Shugart if Dannette Griffith’s preexisting injuries make her more easily injured in a collision even without much property damage, and Dr. Priewe will tell us that because she had a prior neck fusion, the prior injuries make her a very delicate person and that the fusion is strong, but it causes more stress above and below the part that’s frozen. And this puts her at risk for some type of trauma. I asked Dr. James about a prior surgery being a risk factor to make Mrs.Griffith more susceptible to injury, and he’ll tell you that, yes, that is one of the reasons that she has a problem.

Another issue regarding this case is the treatment she received and whether they have helped her or have kept her stable, from getting worse. Now, your verdict form at the end will ask how much money you will allow in your verdict, and to figure that out, you can take nothing into account except the harms and losses, nothing else. So Mr. Fisher, the defense attorney, agrees; and at the end, Judge Williams will tell you that it’s the law, the harms and losses. Everything else is outside the box. So all we’re looking at is the harms and losses in the box. So I need to show you these harms and losses and how severe they are, and I’m not showing you the harms and losses for sympathy because sympathy is outside the box; only the harms and losses are in the box. Sympathy is not something you’re supposed to use or should not use to factor.

Now, you can feel sympathy, you can experience it, but that’s not part of what goes in the box or in the verdict. All right. So during the trial, here’s what you’re going to hear a little bit about the harms and the losses. You’re going to hear that before this collision, Dannette Griffith was a very hardworking, active person. She lived a very healthy normal life. You’re going to hear that back in 1990-something she was involved in a motor vehicle collision where she was a pedestrian at an air show in Fort Wayne, Indiana, and a car hit her. She had injured her Achilles tendon when a car was leaving the air show and hit her or was coming in and hit her, and she got injured. And ultimately she got surgery by Dr. Shugart in Fort Wayne, Indiana, and he fused her neck. After that surgery in the 1990s, she lived a very healthy, active lifestyle riding motorcycles.

Opening Statements in an actual trial in a personal injury case in Florida
Opening Statements in an actual trial in a personal injury case in Florida

She got a job with Terminix. You’re going to hear from some of her coworkers and employer at Terminix of what a hard worker she was. You’re going to hear that she would crawl through basements; she would crawl in attics. She was looking for termite damage in homes and buildings. She would measure the building, and she would calculate how much it would cost and how long it would take to do this type of job. You’re going to hear that she made a good living. However, at the day of the collision, the evidence is going to show that she was working for Terminix. And right after the collision she called her boss, and she took all the steps that her employer told her to take, one of which was to see the workers’ compensation doctors that treated her for this case. And you’re going to see some of those records come into evidence.

You’re going to find out that eventually the neck injury and the low back injury that she sustained from this crash caused her to work less and less and required more physical therapy, more medication until ultimately her condition has continued to decline to the point that she’s totally unable to work. That’s going to be one part of the thing. Another part of the case is you’re going to see and you’re going to have the evidence from the Clerk of the Court about the medical bills, and I expect these to go into evidence, and these are just the bills; these aren’t the records, and you’re going to see that she’s been to the hospital many times. She’s been to surgery centers. She’s had MRIs. She’s had treatments. She’s had Botox injections.

You’re going to find out that the total medical bills in this case are right over $200,000, and that’s not including any invasive surgery, just the surgery from the injections that she’s given to by her surgeon. You’re going to also hear that she’s going to need future medical care for the rest of her life, that she needs to get the Botox injections to help her with the neck. She has this condition that is caused by trauma, and there are other possible causes for it, but trauma is the main one. Something that’s important is because this is a case that involves injuries before and injuries after, I’m going to help you establish the difference, and the evidence is going to show that before the collision of 2007, Mrs.Griffith had temporary back pain. You’re going to find that now it’s permanent.

Before, it would kind of come and go. She was able to climb ladders, do her job, that sort of thing. Now, she’s not able to work, and she has to wear sort of a brace. They call it like a turtle brace around your spine and low back to keep it stable. You’re going to hear that before the motor vehicle collision that we’re here for, she had temporary neck pain. It would irritate her a little bit. She would take Advil. She would do certain things to stretch and exercise it, but she could manage and do pretty well. You’re going to hear now that it’s a permanent neck injury and that as a result, she has this condition where it causes her muscles to go into an extreme spasm and rotate her head and cause all kinds of difficult probleMs. Before this collision, she took no heavy medications: Advil, Tylenol, aspirin, maybe Flexerils, really low, low tough — low-powered medications.

You’re going to hear that after the crash, that they put her on extremely powerful narcotic medications. She takes morphine now, and before she took Dilaudid. And you’re going to hear that Dilaudid is a synthetic morphine and it is five times more powerful than morphine. And you’re going to hear from Dr. James that when he saw her — you’re going to hear from Dr. James who’s a pain management doctor. He’s going to explain to you that he did not like her taking Dilaudid, and he very carefully weaned her off Dilaudid, stopped her taking Dilaudid. And over his care and treatment over the past couple of years, he’s been able to reduce the amount of morphine she takes to a very low level. You’re also going to find out that these narcotics are the best form of treatment for her. You’re also going to hear that Dr. James, who’s a pain management doctor, fellowship-trained anesthesiologist, and only does pain management, that he’s taken Mrs. Griffith to surgery about four or five times, and they do what’s called an epidural steroid injection.

They take a very long needle, and they look at the needle under X-ray live on the TV screen, and they put the needle in the spine very carefully, and they get into the thecal sac or around it, and they inject kind of a Novocain type of medication and then a steroid to help reduce the inflammation of the nerves. Because when the nerves swell up or they inflame, they swell up, and when they swell up, they bump into the tight spaces in her spine, and that causes a cycle of pain. And it just keeps going around and around, and only by these injections can it break the cycle of pain, and you’re going to hear that she has to undergo these shots, you know, a couple times a year when it really gets bad. You’re going to hear that before this collision, obviously Ms. Griffith was driving her car.

She was driving from work, doing things. You’re going to hear that slowly as her health has declined, her spine has declined, her neck problems, her stiffness has increased, that she’s been less and less able to drive a car. And you’re going to see one of the records that’s going to go into evidence is that they gave her a driving test to see how she was doing. And about a year ago, they passed her and said, you know, You’re okay to drive. It’s kind of interesting that they gave her that test. Unfortunately, as time has gone by, they’ve taken her driver’s license away, and you’re going to hear that. That’s one of the differences before and after. So when we talked about aggravation of a preexisting condition, we’re not saying, Hey, she’s — we’re not asking for things about the temporary neck pain, temporary back pain, that sort of thing.

Opening Statements in an actual trial in a personal injury case in Florida
Opening Statements in an actual trial in a personal injury case in Florida

You’re going to find out that before this collision she was able to go outside and work in her garden and take care of her yard and a pool and her dog. You’re going to hear that now she’s lost so much mobility. She can’t drive. It’s very difficult for her to walk. She’s somewhat become cut off from her family and her friends. It’s very difficult for her to get out and interact with people which is an important part of her life. You’re going to find that before this she had lots of friends and a very active social life, and now she’s homebound. Before this, the evidence is going to show that she went to the store. She cooked her own meals. She did whatever. And now she gets her meals delivered to her by Meals on Wheels. So these are the differences before and after that are important.

And we’re not asking for compensation for the problems that she had before. There’s going to be some grey areas in this trial and evidence and certain things where you’re not going to be sure whether it’s an aggravation of a preexisting condition or it was old, and I submit that when you get to the grey areas, go on the side of caution. Don’t worry about it. You can write that off. It’s sort of outside the box. If it’s an aggravation and it really is worse, it’s in the box, and that’s what we’re here to show you the harms and losses are for. Can we turn the projector on? There’s going to be — you’re going to hear a lot of evidence about physics and cars and how they move, and I’m going to just give you a little diagram to help you understand the evidence that you’re going to see. And this is g-forces.

Objection, Your Honor. Argumentative. Well, phrase it in terms of what you anticipate your witnesses are going to show. I anticipate that you’re going to hear from two experts, ours, William Sokol, and from their expert, Dr. Ipser, that there are g-forces, and that this — this is time moving this way, and we’re going to call that zero, and we’re going to call this maybe 5 Gs. And we’re going to call this . 025 seconds. Very, very, very short period of time. Okay. This isn’t ten seconds, five seconds, four seconds. You’re going to hear that at the point of impact when one vehicle hits another vehicle, the target vehicle begins to move and what happens is over time, it accelerates, and then it begins to slowly decelerate. And that’s — that’s because steel on steel, bumper on bumper, metal on metal, the car starts to move. The evidence is also going to show that when a car is hit from the front — and I use this — it’s kind of difficult to see. This is the car, and this is the occupant.

What happens is the car begins to move, but through the laws of inertia, the occupants stand still. She’s sitting in her seat, and the seat’s moving under her, but the laws of inertia prevent her from moving. But what happens is the car starts to move far enough that the seat belt, the shoulder harness, grasp her torso, and they begin to accelerate her torso. So what happens is there’s a little bit of delay in time, and then the torso begins to accelerate. Now, what’s interesting is the torso, because it’s delayed in the acceleration, it has to catch up to the car, and that’s why it accelerates faster. So one car’s accelerating over a longer period of time. The torso is accelerating over a shorter period of time, so it has more g-forces, and then what happens is — Objection, Your Honor. — the evidence will show -. Well, you’re going to have to — look. He’s not the witness.

Right. He’s going to tell you — he’s telling you now what he thinks his witnesses or his evidence is going to show. So when you look at that and you listen to him, put it in that context. Thank you, Your Honor. All right. Go ahead. What happens is the seat belt begins to pull the person back, and the torso is here, and the head, which is connected by the neck, is free floating as well. And the laws of inertia say the torso moves first. The head remains still in space for a little bit until the neck grabs it and then catches it up. So what happens is there’s another slight delay, but then the head has to catch up quickly to the torso, and that’s why it accelerates much faster, and the connecting force between the torso and the head is the spine. And the evidence will show that this is the mechanism of injury.

The evidence will show that she was stopped. The car moves first, the torso gets jerked and then the head, and then it goes backwards and forwards. So this whole diagram goes the other way just as well, and that’s what causes the trauma and injuries to her. Now, the harms and losses are going to be explained by a couple of people. Mr. James Eubanks is a friend and coworker of hers. He’ll be here to tell you how her life was before and how it changed. You’re also going to hear from Dr. Fred Lee who was her boss at Terminix, and you’re also going to hear from a lady named Iris Eastman who is her neighbor. Mrs. Griffith will come in here; she’s going to tell you about her prior neck surgery and the other accidents she’s had. She’s had a couple other accidents; the one, obviously, that caused the surgery. She’s had a couple accidents.

Opening Statements in an actual trial in a personal injury case in Florida
Opening Statements in an actual trial in a personal injury case in Florida

One was a car accident; it was her fault. One was one where it wasn’t her fault. She’s had some treatment, and you’re going to hear, the evidence will show, that after every one of these accidents, she did very well. You’re going to hear after this car accident she declined regularly and that she was given a lot of medication including the Dilaudid and that Dr. James is going to explain that the medication caused her to get dizzy, and she fell out of a chair and then will suggest that that’s a possible aggravation. And the — Judge Williams is going to tell you that if there’s something else that’s added to it that’s caused by it, that’s fine, you’re allowed — that’s inside the box. All right. So from the beginning to the end, everything I show you in this trial is to see — well, let me go back to a couple of things before I end.

It’s important to understand — I shouldn’t put my notes there; I apologize. That’s a photograph of the median, and the evidence is going to show that Mr. Baptiste’s front tires were stuck over that yellow line you’re looking at up there. Here’s another picture from a little different angle, and here’s a photograph of the actual zoomed in curb, and you’ll have these photographs for you back in evidence. This is probably the best one. The other thing that’s important for you to see, and you’re going to probably see this a lot, are the photographs of the property damage, and they don’t really do justice here. That’s the front of her vehicle, and when you get to see the actual photograph closely, you can see that there’s not much damage. However, the radiator got pushed in and was damaged to the point that it was leaking, and it overheated the next day. It wasn’t apparent on the date of the crash. There’s maybe a little better picture of the damage to that.

It’s also important to note that this is the back of Dr. Baptiste’s vehicle, and it shows no damage to his Chrysler; there’s nothing wrong with it. This is evidence that we’re putting into evidence so that you can see this and you can measure it, and you can make the ultimate decisions on that stuff. So — you can turn that off. Everything that I show you from the beginning to the end is to help you understand the harms and losses that are caused by this collision. By the end of the trial you’ll see why this evidence makes this the kind of case in which I have to come back later and ask for an amount of money that right now might seem kind of high. But after the evidence, you will see why the harms and losses are so bad. Thank you very much for your time. Thank you, Your Honor. Okay.

All right. Defense? Thank you, Your Honor. May it please the Court, Mr. Powell? Thank you. Good morning. Thank you for being here; Dr. Baptiste thanks you. And I would like to start first with talking about this accident which happened back in 2007, and we’re going to show you some photos so that you get an idea of what we’re working with here, where the accident happened. This is — can you see this? Okay. Very good. This is the scene of the accident. This is where the accident occurred back in June 6th, 2007. The evidence does show you that Mr. Baptiste backed into the vehicle that Ms. Griffith was driving; there’s never been a dispute about that. The evidence is going to show you that Mr. Baptiste did not get his vehicle stuck on this — on this median here.

He — he intended to cross the street to get some tailoring work done, and he — when he noticed that when he started to turn left that he was going the wrong way, he stopped his car, and he backed up. Now, how far did he go up onto this — onto this median? His tires rolled up onto the median. His left tire rolled up onto this median section a little bit, and that’s when he — he realized, Hey, I can’t do this. That’s what the evidence is going to show you; that’s what Dr. Baptiste will tell you. Now, the only people that were there that witnessed this accident that were parts of this accident were Dr. Baptiste and Ms. Griffith. You’re going to hear testimony from both of them.

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I think the evidence will show you that the more compelling evidence for you to consider is Dr. Baptiste’s testimony that, indeed, what he did was he rolled up onto, slightly, the curb, and then he realized he had to back up, and he backed up. And he’s going to testify to you that he backed up a short distance, and he admits that he didn’t see her. She — she was coming out of the — trying to get out of the parking lot. By the time he put the car in reverse and he backed up his car, she was there, and he backed up into her. It was a short distance that he had to back up to bump into her car. This is a photograph of Dr. Baptiste’s vehicle that he was driving at the time that shows absolutely no damage, no property damage. There — there’s some blowups that show there might be a scrape on the bumper, but that’s it; there’s no property damage.

The evidence is going to show you through our expert and Dr. Baptiste’s testimony that this was, indeed, a low impact accident of — on the order of five miles per hour or less, and that’s — that’s what the evidence shows through these photographs. Here’s a photo of Ms. Griffith’s Cadillac taken right after the scene — right after the accident at the scene or near the scene. Now, you’re going to hear different testimony from the experts in this case. The accident reconstructionist, Dr. Ipser, has a Ph.D. in accident reconstruction, and he will show you what the actual forces of the impact were that my client’s vehicle when he backed up into Ms. Griffith’s car actually was, what the actual force was on the body. Now, you’re going to hear some testimony about there being crush damage and — to the grill and to the radiator, but the evidence is showing you that there has been no damage from this accident that we’re here for to Ms. Griffith’s vehicle. So the defense in this case will center on the low impact nature of this accident, and through our expert testimony of Dr. Ipser will show you that, indeed, the injuries that would have been sustained from this accident are what the medical evidence is going to show you.

Opening Statements in an actual trial in a personal injury case in Florida
Opening Statements in an actual trial in a personal injury case in Florida

The medical evidence is going to show you that this, indeed, was a minor exacerbation of a preexisting condition, myofascial pains to the neck and the low back area, which would have resolved within a certain time frame. And how do we know that? Well, the evidence is going to show you that — that she treated with her workers’ compensation doctor, Dr. Herman. And we — we deposed Dr. Herman, and you’re going to see his Article. Dr. Herman examined her several times, and he came up with the opinion that it was a temporary exacerbation of a preexisting medical condition. By November 20th of 2007 which would be, what, five — five months later, he — he stated that she had made a tremendous recovery. He found no acute disk herniations or major trauma associated with the accident. He found no permanent injury from this accident.

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Now, we also have a medical expert that you’ll — that you’ll hear testimony from, Dr. Harper. Dr. Harper is an orthopedic surgeon. On our request he did a medical examination of Ms. Griffith, and what’s important here is that Dr. Harper looked at her medical records, which include the medical records and the medical history of what was going on with Ms. Griffith before this — this accident that we’re here for, and he — he comes up with the conclusions and impressions after looking at her — you’ll see them. They’re going into evidence, the medical records, so you’ll have a chance to see this for yourself, the — what really was an extensive medical treatment history before this accident occurred. And he — he comes up with — with his impressions of what did this accident cause and the time line that he’s working with in seeing the life of Dannette Griffith and what sort of injuries and accidents that she had before the accident we’re here for today.

And he — he put that together with how did she come out with — from her physical examinations and treatment that he gave her. And Dr. Harper finds no objective evidence of any new permanent injury as a result of this accident. He as well finds that it’s a — he calls it an exacerbation of a preexisting condition. And, now, he does — he does find — and I think this — this goes to Dr. Harper’s testimony in an important way. He does find that she does need remedial care. He’s not saying that she — she doesn’t need something. The woman needs some help, but the future care and the treatment, the remedial care and treatment he does not find is a result of this low impact accident. Now, we also retained for this — for this case a neurosurgeon, Dr. James Schumacher, and he’s going to also give his testimony to you, and you’re going to hear him on the stand.

And he as well looked at all of her medical records, at all of the history that went on before our accident and after our accident, and he’s going to base his opinions on that full medical history, and he’s going to base his opinion on the actual physical examination that he gave her as a neurosurgeon. And he’s — the evidence is going to show you that Dr. Schumacher’s opinion was that she sustained an aggravation of a preexisting condition, but she did not sustain any objective neurologic deficit, and he will testify that further treatments are not necessary due to this accident. Well, after — after our accident, Ms. Griffith, the evidence will show, was also involved in other incidents for which she received treatment and medications. She followed up with her pain doctors after our accident, Dr. Priewe, Dr. James. And at one point, Dr. Priewe, the evidence will show, actually dismissed her as a patient because of noncompliance with his treatment as a pain treatment doctor.

You’ll see in the evidence that Ms. Griffith, when she goes to her doctors after our accident, she doesn’t talk about these other accidents she’s been involved in. She focuses on this accident as a cause of all her problems, not — not these other accidents that she’s been involved in. So the evidence is going to show she was involved in a significant accident of December 24th, 2002, in which she was involved in a rear-end accident, and she — she received treatment and medications for that accident. She had — before that, she had her cervical fusion. She had her cervical fusion in 1990 — in 2000, after the incident in which she was a pedestrian and was — was struck by a car, and she ultimately had that cervical fusion with instrumentation in the year 2000. And she also had a condition before this accident, an injury in which she injured her ankle.

It wasn’t from the pedestrian incident when she hurt her neck, but she had an incident where she hurt her ankle when she’s a bartender in Indiana, and she had ankle surgery before our accident. So she’s living up in Indiana. She comes — she has this accident in 1999 and the ankle injury. She had surgeries for those, and then she moves into Florida and comes into Sarasota, and she’s involved in these other accidents, the significant December 24th, 2002 accident when she was hit from behind, injured her neck and back. The records will show you — there’s a lot of medical records in there that show all the MRIs and all the doctor treatment and all of the opinions about what that accident — accident caused. And she was also in a September 27th, 2004 motor vehicle accident in which she rear-ended another vehicle and, again, was injured and, again, had this neck, back problem, ongoing pains and had the treatment, had the MRIs, had the full workup for that accident.

And she’s taken some significant medications, the evidence will show, after that accident. The medical records show that she also was involved in a November 28th, 2005 slip and fall for which she went to the doctors for treatment, and then — and then we have our accident. So Ms. — Ms. Griffith, indeed, had a long history of previous injuries, accidents for which she sustained permanent injuries from which she received heavy medications and full treatment and workup. Now, I think it’s telling, the evidence — well, take that back. The evidence will show that when she goes to her pain management doctors after our accident, she doesn’t relate any of these other accidents that I just was telling you about, which were significant accidents. And you’ll hear that doctors believe that it’s important to take a full history from a patient when they come in and sit down with them and tell them, Hey, what’s the matter with you? Why do you feel like this? She told the doctors only about this accident.

Opening Statements in an actual trial in a personal injury case in Florida
Opening Statements in an actual trial in a personal injury case in Florida

Now, the doctors have to — they’ll say, the evidence will show, I think she has her ongoing needs for treatment and has the injuries that I find due to what she tells me. They didn’t look at the full — the full big picture, all the medical records and — and they did not, the evidence will show, get a full picture of Ms. Griffith. Now, the evidence is also going to show after our accident she’s had several fall down accidents. And what happens is, as the evidence shows, is that Ms. Griffith reports to Sarasota Medical — Memorial Hospital in September 14th, 2011, reporting that she tripped and fell. What did they give her there at the ER? Dilaudid. Dilaudid’s a heavy-duty narcotic. Before that, August the 30th, 2011, Sarasota Memorial Hospital, she — she went to the ER claiming that she fell in the bathroom and, again, was given Dilaudid.

November 18th, 2011, she reported to Sarasota Memorial Hospital, and from that accident — or from that incident she told them that dogs pulled the chair from under her; and, again, she was given a prescription of Dilaudid. Now, Ms. Griffith we’re not claiming here — Mr. Baptiste doesn’t want you to believe — Argumentative, Your Honor. I’ll overrule that objection, but note the objection and sort of phrase your opening statement to avoid that. Thank you, Your Honor. The evidence is going to show y’all that this is a woman that does have some problems, but the problems that she has today are not a result of this minor impact accident that didn’t even cause any property damage, and the — the instructions are to give a fair and just award to Ms. Griffith — Excuse me. Argumentative, Your Honor. I’ll overrule that objection. Go ahead. — according to the evidence.

All of the evidence that is going to be presented to you, which is going to be a lot — there’s a lot of evidence that’s on the front end, on the back end, and then where we’re put in — that’s going to show you Ms. Griffith sustained an aggravation, an exacerbation of her neck and back area which could be expected from being in a — in a jolting, perhaps, kind of an incident like this, but she didn’t sustain a permanent injury from this accident. And her current treatments, which include the use of morphine and heavy narcotics, are not a result of this accident, the evidence will show. Now, Ms. Griffith is going to claim that this accident caused her from being able to work anymore. The evidence will show you that she was able to go back to work at a point in time, but things kept happening with her in her life that weren’t a result of this accident, and her — her loss of any claimed income going on into the future isn’t a result of this accident, the evidence will show you.

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Florida Injury Law firm - Personal Injury Attorney
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Up until this point in time now, the evidence shows you that she’s treating with a — with a licensed social worker. She goes to this social worker trying to get her life together, trying to work and better herself. And the evidence is going to show you that while she’s going to this licensed social worker, that she, again, complains of in May 25th, 2013, she reported she was involved in another accident and her pain increased again. I think the evidence is going to show you the — what’s going on here as far as Ms. Griffith, her current need for treatment and medications are not a result of this accident. The — the evidence will show you that she’s had the temporary sprain/strain myofascial injuries, as the evidence will show you, she’s sustained; and at a point in time, the injuries from this accident should reasonably be shown and the evidence does show, that she wouldn’t have had any more need for treatment from this accident. And Dr. Herman stated back in November 20th of 2007 that this accident that we’re here for didn’t cause her to have any more need for — for future — future treatment. Okay. So we thank you, again, for being here, and we — we trust that you’ll come up with a fair and just verdict in this case. Thank you.

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