SUCHOCKI & ASSOCIATES, P. C.6320 SOUTHWEST BLVD SUITE 222

FORT WORTH, TEXAS 76109(817) 338-0088(817) 338-0086

Introduction Qualifications

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

OutlineOutline

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IntroductionIntroduction

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

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ExperienceExperience

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:

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ExperienceExperience

Defective Software Toxic Torts Life Insurance Health Insurance Real Estate Employee/Employer Liability Non-Subscriber Liability

In addition, experience handling cases involving:

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ExperienceExperience

Appellate Cases:

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   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. 2-98-283-CV (Tex.App. – Fort Worth 1999)(not designated for publication) [Judgment affirmed – rear-end collision] Hurley v. Markum, No. 2-97-299-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. 01-96-01139-CV (Tex.App.- Houston [1st Dist.] 1998, pet. denied) not designated for publication) [Judgment affirmed – personal injury on elevatorChapman v. Ford, No. 05-96-00622-CV (Tex.App.- Dallas 1998)(not designated for publication) [JNOV reversed and verdict reinstated – rear-end collision]Allied Erectors Corporation v. Barbara’s 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. 2-93-129-CV (Tex.App.- Fort Worth 1994)(not designated for publication) [Summary judgment affirmed – wrongful death] Deaver, et al v. Dairy Commodities, No. 2-91-191-CV (Tex.App.- Fort Worth 1993) (not designated for publication) [Judgment affirmed – contaminated cattle fee

QualificationsQualifications

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

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Counties where we haveCounties where we have

tried casestried cases

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Counties where we have Counties where we have

handled caseshandled cases

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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 Management

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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 Group

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Cost ManagementCost 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

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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 advancedtechnology

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Cost ManagementCost 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

BackgroundCriminalLegal Pre-exiting injuries

RecordsMedicalIncome Tax ReturnsPersonnel InformationPrevious lawsuits

Discovery of relevant facts Experts

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Production Interrogatories Admissions Authorization for Medical Authorization for Other records Freedom of Information Subpoena Surveillance Online to Court Cases Internet PublicData Investigator Deposition

OralNon-Stenographic

Witness InterviewsTelephoneIn 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 UnitMethod Control

BackgroundCriminalLegal Pre-existing injuries

RecordsMedicalIncome Tax ReturnsPersonnel InformationPrevious lawsuits

Discovery of relevant facts ExpertsLegal Research

Cost ManagementCost Management

Consider the most efficient and cost saving approachNext

Reporting is done according to client requirementsReporting available over a wide spectrum

ReportingReporting

Summaries• Sent by mail• Sent by email

Client access to entire file • Client can view any portion of file• Client can download all of the file

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Reporting is concise and direct and enhanced with visual aids, including photographs, graphs, drawings and medical definitions to facilitate communication

Thank You