SUCHOCKI & ASSOCIATES, P. C. 107 LARSON LANE, SUITE 200B ALEDO, TEXAS 76008 (817) 338-0088 (817) 338-0086

1. SUCHOCKI & ASSOCIATES, P. C.107 LARSON LANE, SUITE 200BALEDO, TEXAS 76008(817) 338-0088(817) 338-0086

2. Outline • Introduction • Qualifications • Board Certification in Personal Injury Trial Law • Experience • Litigation Management • Mini-Focus Group • Cost Management • Reporting Next

3. Introduction Thirty-Two (32) years experience handling personal injury and civil trials: • 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 Next

4. Experience 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: • 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 Next

5. Experience In addition, experience handling cases involving: • Defective Software • Toxic Torts • Life Insurance • Health Insurance • Real Estate • Employee/Employer Liability • Non-Subscriber Liability Next

6. Experience Appellate Cases: • 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 elevator • Chapman 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 Next

7. Qualifications • 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? Next

8. Counties where we have tried cases Next

9. Counties where we have handled cases Next

10. 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 Next

11. 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 Next

12. Cost Management We have a rational methodology for controlling costs that is an integral part of litigation strategy. • Negotiate Rates • Establish Budget • Set criteria for feedback • Interview • Watchdog • Production • Interrogatories • Admissions • Authorization • Subpoena • Online to Court Cases • Internet • PublicData • Investigator • Non-Stenographic Video • Background • Records • Discovery of facts • Experts Control Date Unit The elements are Method Next

13. 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 advanced technology Next

14. Cost Management Method Litigation Tasks 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 • Background • Criminal • Legal • Pre-exiting injuries • Records • Medical • Income Tax Returns • Personnel Information • Previous lawsuits • Discovery of relevant facts • Experts • 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 Next

15. Cost Management Method Control Data Unit • Production • Interrogatories • Admissions • Authorization for Medical • Authorization for Other records • Freedom of Information • Subpoena • Surveillance • Online to Court Cases • Internet • PublicData • Investigator • Deposition • Oral • Non-Stenographic • Witness Interviews • Telephone • In 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 • Background • Criminal • Legal • Pre-existing injuries • Records • Medical • Income Tax Returns • Personnel Information • Previous lawsuits • Discovery of relevant facts • Experts • Legal Research Consider the most efficient and cost saving approach Next

16. Reporting Reporting is done according to client requirements Reporting available over a wide spectrum • Client access to entire file • Client can view any portion of file • Client can download all of the file • Summaries • Sent by mail • Sent by email Reporting is concise and direct and enhanced with visual aids, including photographs, graphs, drawings and medical definitions to facilitate communication Next

17. Thank You