Newsome Melton Obtains $25.9 Million Verdict against Ford and The Baptist Church of New Port Richey for Single Wrongful Death

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I. Screening the Case

A. Practical Concerns

B. Analyzing the Statute of Limitations and the Statute of Repose

C. Potential Claims Involving Vehicles

D. Preserve Everything!

II. Identifying the Parties and Theories of Liability

A. Potential Plaintiffs

B. Potential Defendants

III. Drafting the Complaint

A. Negligence and Strict Liability

B. Warranty Theories

IV. Building Your Case

A. Interrogatories

B. Other Similar Incident Discovery

C. Combatting Stonewalling

D. The Cassisi Inference

V. Trials

A. Jury Instructions

VI. Forms

A. Sample Bench Memorandum of Law Regarding Lavado v. State

B. Sample Bench Memorandum of Law Regarding Time Limits on Voir Dire

C. Sample Complaint — Negligence and Strict Liability

D. Sample Complaint — Warranty

E. Sample DND Letter to Insurance Auto Auctions, Inc

F. Sample DND Letter to Tow Yard

H. SOL and SOR Verification Form

I. Sample Jury Instructions

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OVER $500,000,000 recovered
Newsome Melton has recovered over half a billion dollars for their clients.

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