Matt was the Plaintiff's lawyer in Milo v Murphy who crossed examined the Defendant on his Answer.
This jury trial was tried in Cobb State Court before Judge Prodgers. The Judge was great. State Farm insured the Defendant Murphy.
In the Defendant's Answer to our Complaint he denied responsibility. Lawyers at Sharon Ware and Associates, in house State Farm Lawyers, drafted the Answer for him.
At the first day of the jury trial the Defendant accepted responsibility. The insurance defense lawyer from Downey Cleveland mentioned it in his opening statement.
The insurance defense lawyer wanted the jury to believe that the Defendant had accepted responsibility from day one.
It was important to our case to show the jury that the Defendant had not accepted responsibility from day one.
Melissa Milo suffered a broken ankle that required surgery. She was in her mid thirties at the time of trial . She walked with a limp and her ankle still swelled when she stood for a long time.
We called no medical doctors as witnesses. We used no medical narratives. We introduced no medical records. We did not need the orthopedic surgeon to testify to what a great job he had done in repairing Melissa's ankle.
We did not want the verdict to be a simple multiple of her past medical expenses. i.e. 3 times $30,000 equals $90,000.
We called only three witnesses to the stand: the police officer, the Defendant, and Melissa Milo, the Plaintiff.
We wanted to keep it simple. The jury appreciated that.
We did not ask for any lost wages ( about one year's worth ).
Melissa was a waitress at Shoney's at the time. It would have been difficult to prove her lost wages based on tips. We had no supporting evidence and We did not want to over reach.
A Cobb County Jury of 12 returned a verdict for $536,000 that was for Melissa Milo's pain and suffering damages only."