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A Quick Note Regarding Surveillance Reports in Florida

In Florida, if you want to use surveillance footage at trial, you have to provide a copy to the plaintiff beforehand. After you provide the footage, the plaintiff might seek to compel the private investigator’s report as...more

Additur for Future Pain and Suffering Damages

When a jury’s verdict is unreasonably low, the presiding judge may increase it by awarding an additur pursuant to Florida Rule of Civil Procedure 1.530 and Section 768.74, Florida Statutes. However, as to damages for future...more

A Quick Note about Removal with Less Than $75,000 in Medical Specials

Removing a case to federal court requires diversity of citizenship and an amount in controversy of more than $75,000. In a personal injury case, the easiest way to prove the amount in controversy is to show medical specials...more

11/14/2023  /  Citizenship , Diversity , Medical Expenses

Tips for Young Lawyers: CME Location

You have analyzed the medical records, retained a medical expert and lined up a compulsory medical examination (CME). Then the objection arrives: the plaintiff refuses to attend the exam because it is being held in a...more

A Quick Note about Pain and Suffering Disclosures in Federal Court

In federal court, personal injury plaintiffs are required to disclose a computation of each category of damages. Fed.R.Civ.P. 26(a)(1)(A)(iii). Past medical expenses and past lost wages are easy. But for pain and...more

Automotive and Trucking Accidents in the U.S. with Foreign Defendants: What Insurers Need to Know [Audio]

Attorneys Mike Forte and Vince Saccomando discuss defense strategies for automotive and trucking accidents in the U.S. with both foreign and U.S. defendants. They outline what insurers should know in handling these claims...more

Landowner’s Duty of Care in Florida, and the Special Case of Contractors

In a premises liability case, the landowner’s standard of care is determined by the category of entrant.  Post v. Lunney, 261 So. 2d 146, 147 (Fla. 1972).  See also ARP v. Waterway E. Assoc., Inc., 217 So. 3d 117, 120 (Fla....more

A Quick Note About Florida PIP Setoffs Without PIP Insurance

Generally, Florida drivers are required to carry $10,000 in personal injury protection insurance.  Fla.Stat. § 627.736.  After a car accident, PIP benefits are paid toward the insured’s medical expenses, regardless of fault,...more

Florida Car Accident Lawsuits: How to Apply the Brakes on Plaintiffs

Looking for the Most Generous County - When a Canadian is sued in Florida, moving the case from the Florida state court system to the U.S. federal court system usually is a good move for the defense. But sometimes, making...more

Using Vicarious Liability to Defeat Employer Negligence Claims

In lawsuits involving commercial trucking accidents, plaintiffs frequently sue the driver’s employer for vicarious liability (respondeat superior and/or dangerous instrumentality doctrine), as well as for negligent hiring,...more

Nuts and Bolts of Florida’s Seatbelt Defense

Florida is a popular destination for vacations and second homes.  When a Canadian is involved in a car accident in Florida, blame can be placed on the other driver for failing to wear a seatbelt.  To prevail on the seatbelt...more

Combating Permanency Without A Defense Medical Expert

This brief, practical article presents strategies for challenging claims of permanent injury without relying on a defense expert. Originally published in the Trial Advocate Quarterly, Winter 2018 Volume 37, Number 1. ...more

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