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.)

Dr. Buckner

Date of Surgery: May 31, 2006

Buckner: Not the right doctor for the job

WRONG!

WRONG!

What did Dr. Buckner actually do?

Who are the RSD Experts?

Dr. Buckner

I didn’t know she has RSD.

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

Dr. Buckner

“Swelling?”

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

She also has symptoms of RSD, so I’m sending her to Dr. Elroy

Dr. Munson

Dr. Munson

Dr. Munson

Physical Therapist identified the source of pain in the patellar tendon, confirmed by Munson.

Ms. May

What are the Symptoms of RSD?

• Swelling

• Hyperesthesia (extremely sensitive to touch)

• Temperature changes

• Stiffness

• Color changesDr. Elroy

Apr 2006 Jul 2006 Oct 2006 Jan 2007 Apr 2007 Jul 2007 Oct 2007 Jan 2008

Apr 17, 2006

Ms. Winger hits Ms. Moore

Apr 17, 2006

Pain throughout the leg from the hip down to the ankle (GBMC)

Apr 27, 2006

Globally tender; out of proportion(Buchalter)

May 11, 2006

Continues to have popping and catching of the knee(Buchalter) < Jun 8, 2006

Pain in left leg and calf; swelling in calfWent to ER to rule out blood clots(GBMC)

Aug 24, 2006

Therapy helped initially, but became problematic(Buchalter)

May 31, 2007

Reports that knee gives out about three times a week(Buchalter)

Apr 24, 2006

Swelling & pain in entire leg, tingling sensation(Bucci)

Defendant hits Plaintiff

Jan 2008 Apr 2008 Jul 2008 Oct 2008 Jan 2009 Apr 2009 Jul 2009 Oct 2009

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, patellar-femoral tenderness(Tarantino)

~ Jul 15, 2009

Increased swelling, stiffness, color change(Matthews)

Sep 24, 2009

Pain in entire leg up to hip(Elsamanoudi)

Nov 16, 2009

Temperature changes(Elsamanoudi)

Jul 15, 2009

Increasing pain, more swelling, redness, discoloration(Matthews)

Feb 5, 2008

Global pain; hyperestheticnever back to normal since impact(Tarantino)

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

Ms. May clearly has RSD. She needs a spinal stimulator implant.

The RSD Expert

Dr. Elroy

Dr. Elroy

Dr. Elroy

Ms. May

Ms. May

1. GBMC Emergency Room $ 338.752. Charles Emergency Phys. $ 217.003. Dr. Johnson $ 1,828.00 4. MRI on 05/09/06 $ 1,431.00 5. Dr. Munson $ 3,325.006. Union Memorial Hospital $ 2,283.007. Hereford PT (6/16/06 to 7/5/06) $ 1,230.008. Dr. Elroy $ 3,160.006. Dr. North/Sinai Hospital $35,084.52

TOTAL: $48,897.27

Past Medical Expenses

Lost Wages

04/17/06 to 09/04/06

• Waitressing: 5 weeks $1,225.00 average $245.00 per week

• Lifeguarding: Summer $1,698.88

TOTAL: $2,923.88

FUTURE MEDICAL COSTSLow End High End

• 2019 (age 31) $22,000.00 $28,000.00• 2028 (age 40) $22,000.00 $28,000.00• 2037 (age 49) $22,000.00 $28,000.00• 2046 (age 58) $22,000.00 $28,000.00• 2055 (age 67) $22,000.00 $28,000.00• 2064 (age 76) $22,000.00 $28,000.00

TOTAL: $132,000.00 $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