They wanted him to get secret surveillance video of my client doing something she claimed she couldn't do.
For two solid days, this private investigator stalked my client in a van, taking hidden camera video. They got her on video walking out of her house and into her car. They followed her car to her work. They got her on video leaving her car in the parking lot and entering her workplace.
They followed her movements from the moment she left her work and walked to her car. They followed her car to pick up her kids from school. They tracked her driving her kids home and walking into her house.
The next day they got her taking the trash out and returning inside.
They showed this video to the jury at trial. They used it to show my client didn't have a limp. They showed she could walk. They showed she didn't need a cane or crutch to help her walk. They thought they had her...
The jury saw that they had nothing on her and there was nothing in the video that contradicted anything my client said she couldn't do.
There was one other key thing that contributed signficantly to my client being awarded $1.55 million dollars in Westchester County. Want to know what it was?
I asked the expert where were his notes and cover letter that the defense attorney sent to him along with the medical records to review in this case. The doctor said he left them in his office. In fact, they were sitting on his desk in his office where he left them just the night before.
The doctor refused to acknoweldge that if he brought those notes with him, I'd be able to see them. He finally admitted that he was fully aware that's what happens if he brings his notes to court.
I then said that during the next break, I wanted him to call his office and have his secretary fax to the court the cover letter the attorney sent him.
"Great," I said. "Have your secretary go to your car and fax us the letter right now."
"Oh, I forgot. It's not there, it's at home," the defense expert replied.
That changed everything.