AAJ Exchange Litigation Packet Catalog - American Association for ...

AAJ Exchange 

Litigation Packet Catalog 

Summer 2007 

Formerly the Association of Trial Lawyers of America 

More than 90 packets on: 

Advocacy • Insurance • Motor Vehicle Collision and Auto Products Liability 

Nursing Homes • Toxic and Pharmaceutical Torts • Premises Liability 

Commercial Law/Consumer Rights • Employment Rights • Medical Negligence 

SEE INSIDE FOR SPECIAL OFFER: A $30 SAVINGS!

Topical Index 

Summer 2007

Advocacy 

A Guide Through Preemption ..............................1 

A Guide to Nontraditional Discovery ...................1 

Admissibility of Expert Testimony ........................1 

Damages in Burn Injury Cases ..............................1 

Discovery Strategy: Use of Rules 30(b)(5), 

30(b)(6), and 34 .................................................1 

Electronic Discovery...............................................1 

Ex Parte Access to Corporate Employees: ABA 

Model Rule of Professional Conduct 4.2 ..........1 

Federal Tort Claims Act ..........................................1 

HIPAA and Its Privacy Rules .................................2 

Prove Damages Using Opening Statements 

and Closing Arguments .....................................2 

Settlements: ERISA-Medicaid-Medicare- 

Social Security ....................................................2 

Taking Depositions .................................................2 

Voir Dire and Jury Selection ..................................2 

Wal-Mart Stores, Inc.: Discovery Abuse ...............2 

Commercial Law/Consumer Rights 

Debt Collection.......................................................2 

Mandatory Arbitration ..........................................2 

Employment Rights 

Employment Discrimination Law ........................3 

Pregnancy Discrimination .....................................3 

Sex Discrimination/Harassment ...........................3 

Insurance 

Allstate Automobile Claims ...................................3 

Allstate Claim Core Process Redesign (CCPR) 

Implementation Training Manual (1995) ........3 

Allstate Claim Policy-Practices-Procedures 

Manual, Volume 1 (1994) ..................................3 

Allstate Claim Policy-Practices-Procedures 

Manual (2003) ....................................................3 

Bad Faith: Travelers Insurance 

Company’s Incentive Program ..........................3 

Colossus Claims Evaluation Software ...................3 

Defense Medical Examiner: 

Defusing the Testimony .....................................4 

Farmers Group of Insurance Companies: 

Enterprise Structure and 

Incentive Program ..............................................4 

Farmers Home Group Loss Adjusting Manual 

(August 1995) and Farmers Home Group 

Special Investigative Unit (SIU) Claims 

Manual for AZ (February 1997) .......................4 

Fibromyalgia: The Essentials .................................4 

Fighting ERISA Preemption ..................................4 

Litigating the First Party Bad Faith 

Insurance Claim .................................................4 

MTBI Cases: Insurance Company 

Defense Medical Experts ...................................4 

Unauthorized Practice of Law: 

Jones v. Allstate Insurance Co. ...........................4 

UnumProvident Bad Faith: Deposition and 

Trial Transcript Collection ................................4 

UnumProvident Bad Faith: Occupational 

Stress Deposition Collection .............................5 

UnumProvident Corporation Customer Care 

Center Claims Manual (April 2001) .................5 


Center Claims Manual (November 2002) ........5 

Workers’ Compensation Bad Faith: 

AIG and American Home Assurance 

Incentive Programs ............................................5 

Motor Vehicle/ 

Automobile Products Liability 

Automobile Data Recorder: 

Litigating the “Black Box” Issue ........................5 

Crashworthiness Cases ...........................................5 

Firestone Tire Tread Separation ............................5 

Interstate Trucking: 

Independent Contractor Defense ....................5 

Interstate Trucking Regulations, 

Discovery, and Damages ....................................5 

Low Speed Impact and 

Connective Tissue Injuries ................................6 

Preparing a Motor Vehicle Collision Case ............6 

Nursing Homes 

Discovery Abuses: Lessons Learned 

in Nursing Home Cases .....................................6 

Nursing Home and Assisted-Living 

Facility Mandatory Arbitration .........................6 

Nursing Home Litigation: 

Inadequate Staffing ............................................6 


Lavalis v. Copperas Cove, L.L.C. .......................6 

Nursing Home Litigation: Manor Care 

Management Deposition Collection ................6 


Negligent Hiring.................................................6 


Nursing Errors ....................................................6 

Nursing Home Litigation: Standard of Care 

Expert Deposition Collection ...........................7 

Pressure Sores .........................................................7 

Premises Liability 

Home Depot USA, Inc.: 

Falling Merchandise ...........................................7 

Marriott Inadequate Security and 

Litigation Abuse .................................................7 

Secondhand Smoke Liability .................................7 

Wal-Mart Stores, Inc.: 

Falling Merchandise ...........................................7 

Wal-Mart Stores, Inc.: 

Inadequate Security and Litigation Abuse .......7 

Wal-Mart Stores, Inc.: Premises Liability 

(Shooting) and Litigation Abuse ......................7 

Wal-Mart Stores, Inc.: Slip and Fall.......................7 

Products Liability 

Bed Rails: Dangerous Devices ...............................7 

Heart Device Recalls ...............................................8 

Tasers: Unsafe and Lethal .......................................8 

Medical Negligence 

Birth Injury Cases: Shoulder Dystocia 

Expert Deposition Collection ...........................8 

Birth Injury Cases: Shoulder Dystocia ..................8 

Failure to Diagnose Breast Cancer ........................8 

Failure to Diagnose a Pulmonary Embolism .......8 

Fetal Distress Signs and Failure to Timely 

Perform a Cesarean Section ..............................8 

Hospital-Acquired Infections ................................9 

Injured Infants: Failure to 

Diagnose Meningitis ..........................................9 

Laparoscopy: Minimally-Invasive 

Abdominal Surgery ............................................9 

LASIK ......................................................................9 

Life Expectancy and Neurological Injury: 

Defense Experts ..................................................9 

Litigating Gastric Bypass Cases .............................9 

Medication Errors ..................................................9 

Nursing Errors in Hospitals ...................................9 

Pharmacy and Pharmacist Liability ......................9 

Surgical Negligence: Retained Towel ...................10 

Toxic and Pharmaceutical Torts 

Bausch & Lomb ....................................................10 

Bextra.....................................................................10 

Fen-Phen ...............................................................10 

Fosamax, Zometa and 

Other Bisphosphonates ...................................10 

Hormone Therapy Litigation Packet ..................10 

Kugel Mesh Litigation Packet ..............................10 

Lead Paint Litigation: Landlord and 

Manufacturer Liability .....................................10 

Lotronex ................................................................10 

Methyl Tert-Butyl Ether (MTBE)........................10 

Ortho Evra ............................................................11 

Pharmaceutical Products Liability Cases ............11 

Rezulin ...................................................................11 

Selective Serotonin Reuptake Inhibitor 

(SSRIs) and the Link to Suicide .....................11 

Toxic Mold ............................................................11 

Vioxx ......................................................................11 

Vioxx Update ........................................................11

Advocacy 

A Guide Through Preemption 

[UPDATED July 2007; 1,034 pages] 

• Briefs from a variety of cases arguing against 

defense motions for summary judgment on 

preemption grounds 

• Orders from various jurisdictions denying 

federal preemption 

• Strategies on avoiding preemption 

• Statutes and case law from relevant practice areas 

• Overview of federal preemption 

• Discussion of federal preemption in 

pharmaceutical, medical device, auto safety, 

aviation, and railroad cases 

A Guide to Nontraditional Discovery 

[UPDATED September 2006; 337 pages] 

• How to gather information without the 

involvement of the defendant 

• People, Businesses and Assets 

• Literature and Intellectual Property Searches 

• Litigation History 

• Health Care Facilities and Practitioners 

• Product, Workplace and Transportation Safety 

• Trade and Industry Organizations 

• Government and Foreign Jurisdiction Resources 

Admissibility of Expert Testimony 

[UPDATED June 2007; 1,132 pages] 

• Created with assistance from AAJ’s Daubert 

Litigation Group 

• Discussion of Daubert, Frye and other 

expert admissibility standards 

• How to use Daubert and other expert 

admissibility rules as a sword 

• How to “Daubert-proof” your experts 

• Sample motions, briefs, depositions, expert 

report and other court documents 

• Table providing state-by-state 

analysis, with accompanying case law and 

statutory references 

Damages in Burn Injury Cases 

[February 2007; 274 pages] 

• Management of the issues unique to burn 

injury casesIntroduction to the biology and 

medical treatment of burn injuries 

• How to effectively document and present the 

full extent of burn injuries and associated 

damages, including real case examples 

• Sample court documents (complaint; 

settlement and pre-trial memoranda; jury 

instructions and interrogatories; and opposition 

to defense motions for bifurcation and 

exclusion of photographic evidence) 

• Burn treatment guideline summary, 

glossary of medical terms, illustrations 

and Internet resources 

• AAJ Education speaker papers 

Discovery Strategy: Effective Use of Rules 

30(b)(5), 30(b)(6), and 34 

[UPDATED December 2006; 816 pages] 

• Illustrates the interplay between 

Fed.R.Civ.P. 30(b)(5), 30(b)(6), and 34 

• Sample Notices of 30(b)(6) depositions, 

plaintiff interrogatories, stipulation 

and order for deposition protocol, 

and statement of authority regarding 

deposition protocol 

• Court Documents including depositions, 

motions, and orders from an interstate 

trucking case and two nursing care facility 

cases that illustrate how 30(b)(5), 30(b)(6), 

and 34 can be used in conjunction 

• Using 30(b)(6) to produce incident 

reports and elicit electronic information 

[Deposition summary accompanies 

each deposition transcript] 

Electronic Discovery 

[UPDATED November 2006; 493 pages] 

• Fundamentals: types of ESI and the 

role of a computer forensics expert 

• Electronic discovery checklist 

• How to use discovery requests to elicit 

relevant ESI; whom to depose under 

Rule 30(b)(6) and what to ask 

• How to preserve ESI and avoid spoliation 

• Discussion of the ESI-related amendments 

to the Federal Rules of Civil Procedure 

• Case law on pivotal issues, such as cost 

shifting, spoliation, sanctions, and privilege 

Ex Parte Access to Corporate Employees: 

ABA Model Rule of Professional Conduct 4.2 


• An in-depth, state-by-state analysis of 

the application of Rule 4.2 for all 50 states: 

the version of the rule applied, interpretive 

case citations, and case summaries in a 

variety of practice areas 

• Strategies on the use of Rule 4.2, including 

sample questions for former and current 

corporate employees 

• Illustrative motions, memoranda, and 

orders regarding access to former and 

current corporate employees in nursing 

homes and medical malpractice cases 

Federal Tort Claims Act 


• Outline introduction to the FTCA 

• Full text of the FTCA (28 U.S.C. §§ 

2671-2680) and excerpts of the various 

applicable statutes 

• Standard Form 95, Freedom of Information 

Act records request checklist, FTCA sections 

of the U.S. Attorneys’ manual, and example 

agency regulations and FTCA handbooks 

• Court documents (complaint, discovery plan, 

pretrial order, response to motion to limit testimony 

of the treating physician, choice of law 

brief, and findings of fact and conclusions of law) 

• Deposition transcripts and summaries 

of treating physicians and expert witnesses 

in claims against U.S. military hospitals 

• Sample stipulation for compromise settlement 

and release of claim, and irrevocable 

reversionary inter vivos medical trust 



1 www.justice.org/exchange | 800-344-3023 | 202-965-3500, ext. 615

HIPAA and Its Privacy Rules 

[UPDATED June 2007; 690 pages] 

• Overview of common HIPAA issues 

facing trial lawyers 

• Statutory and regulatory materials 

including information on how to file a 

privacy complaint 

• HIPAA authorization and releases, letters 

to health providers, protective order 

motion and memorandum, compliance 

letter, and related litigation materials 


Prove Damages Using Opening 

Statements and Closing Arguments 

[August 2006; 768 pages] 

• Addresses all aspects of damages including 

how to craft persuasive opening statements 

and closing arguments, storytelling, structure, 

theming, and more 

• Opening statement transcripts from a nursing 

home case, a highway defect case, and a birth 

injury case 

• Closing statement transcripts from a motor vehicle 

collision case, a trucking auto crash, medical 

negligence case, and two birth injury cases 

Settlements: ERISA-Medicaid- 

Medicare-Social Security 

[November 2006; 408 pages] 

• Effectively solve a client’s financial problems 

while avoiding settler’s remorse and professional 

liability complaints 

• How to identify alternative financial 

solutions, maximize funds, and preserve 

government benefits 

• How and when to address liens, 

subrogation, claims for reimbursement, 

and taxation of damages 

• Supplemental Security Income and Medicaid; 

Social Security Disability and Medicare; 

and ERISA Structured Settlements; Special 

Needs Trusts 

Taking Depositions 


• Questioning techniques such as exhaustion, 

restating and summarizing, and boxing in 

• Questioning adverse experts, including 

defense medical examiners and standard of 

care experts 

• The 30(b)(6) deposition and its role in 

your overall discovery plan 

• Depositions from several practice areas 

including: interstate trucking, insurance, 

nursing home, and medical malpractice 

• Deposition from Annette Orlowski 

• Handling abusive tactics 

• Preparing your client for deposition 

• Use of videotaped and telephone depositions 

• Organizing for depositions 

• How to use deposition psychology 

in eliciting answers 



Voir Dire and Jury Selection 

[UPDATED July 2007; 747 pages] 

• Hundreds of sample voir dire questions 

and sample questions and strategies 

on attitudes about lawsuits and damages 

• Addresses full spectrum of cases – auto, 

products liability, medical negligence, 

insurance, toxic torts, employment 

rights, civil rights, nursing homes, and 

business torts 

• Sample supplemental juror questionnaires 

and related motions 

• Techniques to expand voir dire, including 

time allotment and attorney involvement 

• Discussion of peremptories and challenges 

for cause, including questions and 

illustrative state cases 

• Analysis of juror decision making 

and bias and using focus groups as a 

voir dire tool 

Wal-Mart Stores, Inc.: Discovery Abuse 

[December 2000; 217 pages] 

• 28 decisions showing Wal-Mart’s status as 

a discovery abuse “repeat offender” 

• Spreadsheet listing sanctionable conduct, 

sanctions imposed, and judicial comments 

Commercial Law/Consumer Rights 

Debt Collection 


• For the collection attorney and the attorney 

who represents victims of unfair debt 

collection practices 

• The collection process from the 

initial demand to the satisfaction of 

a monetary judgment 

• Fair Debt Collection Practices Act, 

15 U.S.C. §§ 1692-1692o 

• Servicemembers Civil Relief Act, 

50 U.S.C. App. §§ 501-596 

• Sample letters to debtors, payment plans, 

spreadsheets, and client communications 

Mandatory Arbitration 


• Mandatory arbitration clauses in consumer, 

employment, insurance, nursing home and 

assisted living facility contracts 

• Defense motions to compel arbitration, 

plaintiffs’ memoranda in opposition 

to compel arbitration, plaintiff ’s appellate 

briefs, depositions and discovery requests 

• Litigation checklist 

• U.S. Supreme Court case summaries 

National Arbitration Forum (NAF) 

corporate documents 

• Case updates and filings in 

Nagrampa v. Mailcorps, Inc., in 

Discover Bank v. Superior Court of Los 

Angeles County, and in Raymond James 

Financial Services, Inc. v. Saldukas 

Summer 2007 

2

Employment Rights 

Employment Discrimination Law 

[December 2005; 576 pages] 

• Complaints and discovery requests 

from various employment discrimination 

cases including age, disability, and 

sex-based discrimination 

• Summary judgment motions and 

briefs in opposition 

• Employment law statutes and U.S. 

Supreme Court case summaries outlining 

the changing role of a Rule 56 summary 

judgment motion and its application in 

employment rights cases 

• EEOC materials outlining various charges 

of discrimination and information detailing 

how to file a complaint 

• Other topic areas including wrongful 

termination and denial of COBRA 

benefits court documents 

NEW! Pregnancy Discrimination 

[May 2007; 996 pages] 

• How to file a charge of pregnancy 

discrimination 

• EEOC materials outlining pregnancy 

discrimination filing requirements, 

pregnancy-related protections, and 

statutory authorities 

• Complaints and discovery requests from 

various pregnancy discrimination cases 

• Pleadings, motions, discovery abuse, 

jury instructions, posttrial motions, and 

mediation documents 

• Plaintiff’s deposition outlining termination 

from employment after supervisor learns of 

employee pregnancy 

• Pregnancy discrimination statutes and Rule 

56 motion practice 

• Pregnancy discrimination verdicts survey 

• TRIAL article and AAJ Education papers 

• Secondary resources 



Sex Discrimination/Harassment 


• Detailed look at a lawsuit filed by a female 

police officer against her department 

• Guiding commentary and suggestions from 

the lead attorney 

• Key briefs, interrogatories, requests for 

production, and memoranda 

• Expert witness statements and 

correspondence to the EEOC 

Insurance 

NEW! Allstate Automobile Claims 

[July 2007; 2,226 pages] 

• Explores issues of investigation, negotiation, 

discovery, settlement and litigation 

• Analysis of general claims handling of 

automobile bodily injury claims at Allstate 

including MIST, Colossus, UM and UIM claims, 

Special Investigative Unit (SIU) and Allstate’s 

incentive compensation programs 

• Sample court documents: complaints, 

requests for production, motions, oppositions 

and orders regarding protective orders, 

motions for sanctions against Allstate and 

depositions of Allstate employees 

• Explores bad faith and other theories 

of liability 




Allstate Claim Core Process 

Redesign (CCPR) Implementation 

Training Manual (1995) 

[July 1995; 605 pages] 

• Allstate claims training manual with Allstate’s 

descriptions of its controversial tactics 

• Handling unrepresented claimants 

• Minor impact soft tissue (MIST) claims 

• Colossus 

• Special Investigative Unit (SIU) 

Allstate Claim Policy-Practices- 

Procedures Manual, Volume I (1994) 

[January 1994; 159 pages] 

• Portions of the Allstate Claim Policy- 

Practices-Procedures Manual, Volume I 

Updated through January 1, 1994 

Allstate Claim Policy-Practices- 

Procedures Manual (2003) 

[May 2005; 195 pages] 

• Portions of the Allstate Claim 

Policy-Practices-Procedures Manual 

• Updated through January 2003 

Bad Faith: Travelers Insurance 

Company’s Incentive Program 

[UPDATED April 2005; 1,267 pages] 

• Profiles a bad faith workers’ compensation 

insurance case of a 57-year-old nursing home 

employee who developed work-related carpal 

tunnel syndrome 

• Focuses on Travelers Claims Professional 

Incentive Program that rewarded employees 

with year-end bonuses for reducing overall 

insurance payouts 

• Travelers Incentive Compensation Program 

documents from 1998 to 2004 

• Key court documents, deposition of 

Travelers’ insurance expert, full trial 

transcript, and appellate briefs filed in 

Eighth Circuit Court of Appeals 

• AAJ Extras Member Medifocus Legal material 



Colossus Claims Evaluation Software 


• An explanation of Colossus and how it is 

used by insurers to evaluate the values of 

automobile bodily injury claims 

• Deposition testimony from Allstate 

employees explaining Colossus and 

incentives for claims adjusters 


• Trial testimony, including cross-examination 

of the Colossus software licensor, about 

how the software is “tuned” according to 

insurer specifications 

• Sample requests for production 

on the Colossus issue 

• Farmers class action settlement 



Defense Medical Examiner: 

Defusing the Testimony 


• Court documents and depositions of several 

DMEs, illustrating how to exclude or neutralize 

the DME’s testimony and expose DME bias 



Farmers Group of Insurance Companies: 

Enterprise Structure and Incentive Program 

[UPDATED April 2005; 1,318 pages] 

• 30(b)(6) depositions of the Farmers employee 

most knowledgeable about corporates 

structure, the claims incentive program and 

accounting of premiums paid by insureds 

• Briefs on the issues of punitive damages based 

on the claims incentive program and Farmers’ 

liability as a single business enterprise 

Farmers Home Group Loss Adjusting 

(August 1995) and Farmers Home Group 

Special Investigative Unit (SIU) Claims 

Manual for Arizona (February 1997) 


• Information on property and casualty 

claims handling 

• SIU claim jurisdiction 

• Indicators of potential fraud and more 

Fibromyalgia: The Essentials 

[May 2005; 240 pages] 

• Medical and legal fundamentals of 

litigating fibromayalgia claims 

• Court and arbitration materials including 

opposition to motion in limine 

and treating physician deposition 

• Tender points quick reference and graphic, 

and illustrations 

• NIH patient publication and diagnostic 

guideline summary 



Fighting ERISA Preemption 


• How to avoid ERISA preemption 

• Case law update for Jan 2002-Sep 2005 

Litigating the First Party Bad 

Faith Insurance Claim 

[December 2006; 1,020 pages] 

• Guide to litigating first party bad faith 

insurance claims whether based on property, 

disability, workers’ compensation or health 

or accident policies 

• Client interview and other pre-suit 

considerations, plus filing the claim, 

discovery, voir dire, and jury selection 

• Addresses ERISA, common defenses, 

genuine-issue rule, damages 

• Sample documents: complaint, depositions 

of claims adjuster, corporate designee, 

and defense expert, motions to compel, 

interrogatories, requests for production, 

requests for admission 

• Checklists: causes of action, deposition 

questions for claims adjusters and 

supervisors, requests for production 



MTBI Cases: Insurance Company 

Defense Medical Experts 

[January 2004; 1,498 pages] 

• How to effectively cross-examine 

defense experts on their 

neuropsychological techniques 

• Depositions of insurance company 

defense neuropsychologists, psychiatrists, 

and neurologists 



Unauthorized Practice of Law: 

Jones v. Allstate Insurance Co. 


• Tactics for beating Allstate at its own game 

from the lead attorney in Jones v. Allstate 

• “Smoking gun” corporate documents 

as well as strategies on how to use them 

• Allstate’s use of its controversial Claim 

Core Process Redesign (CCPR) policy to 

discourage claimants from hiring a lawyer 

• Allstate’s liability for unauthorized practice 

of law and resulting damages 

• Settlement between the parties invalidated 

and decision upheld on appeal 

UnumProvident Bad Faith: Deposition 

and Trial Transcript Collection 


• A must-have for lawyers with cases against 

UnumProvident 

• Testimony from current and former 

employees and consultants, including 

physicians, executives, and claims adjusters 

• A look into the “roundtable,” the 

controversial claims handling process 

• Deposition summaries and transcripts 

of claims consultants, claims examiners 

and an appeals specialist from the case of 

Jay Lipshutz, O.O. v. General American 

Life Insurance Company and Paul Revere 

Life Insurance Company 

• Trial and appellate court orders and trial 

testimony from the senior vice president of 

customer care from seminal case Hangarter v. 

Provident Life and Accident Ins. Co. 

• Information on October 2005 class 

action filing 



Summer 2007 

4

UnumProvident Bad Faith: Occupational 

Stress Deposition Collection 

[UPDATED November 2005; 1,044 pages] 

• Own occupation policy 

• Step-by-step analysis of how 

UnumProvident handled the claim 

• Insurer engaged in questionable 

communications with DME who later 

altered evaluation Report 

• Testimony from the DME and company 

claims, vocational, and medical personnel 

• Information on October 2005 class 

action filing 



UnumProvident Corporation Customer 

Care Center Claims Manual (April 2001) 

[April 2001; 542 pages] 

• Long term, short term, and individual disability 

• Long term care insurance 

• Life insurance 

• State law governing claims handling 


Center Claims Manual (November 2002) 


• Expanded version of the April 2001 edition 

• Long term, short term, and individual disability 

• Long term care insurance 

• Life insurance 

• State law governing claims handling 

Workers’ Compensation Bad Faith: 

AIG and American Home Assurance 

Incentive Programs 

[July 2006; 740 pages] 

• Profiles a bad faith workers’ compensation 

claim where the carrier and its third party 

administrator denied benefits based on an issue 

of new accident versus need for further medical 

treatment in relation to a prior accident 

• Substantial verdict against AIG 

• AIG found fully responsible for breach of its 

duty and liable for life-time medical care and 

disability benefits 

• Plaintiff produced evidence that defendants 

received financial incentives to cut claim 

costs rather than focus on fair evaluation of 

compensable claims 

• Contains key court documents including: 

Plaintiff’s Initial Disclosure Statement, 

Plaintiff’s Requests for Production of 

Documents, Plaintiff’s Statement of Facts, 

Plaintiff’s Motions to Compel for Production 

of Documents, Plaintiff’s Motion for Partial 

Summary Judgment on Issues of Bad Faith, 

Plaintiff’s Reply Briefs on Motions to 

Compel and for Sanctions, and more 

• Deposition transcripts and summaries 

from AIG employees involved in all aspects 

of claims handling 

• Deposition transcripts and summaries from 

the Plaintiff Insurance Expert and a trial 

transcript and summary from the Plaintiff 

Orthopedic Surgeon 



Motor Vehicle/ 

Automobile Products Liability 

Automobile Data Recorder: 

Litigating the “Black Box” Issue 

[UPDATED March 2006; 685 pages] 

• Technical explanation about how 

the black box works 

• Strategies on preservation and downloading 

of data, use of experts, ownership of data, 

and other issues 

• Discovery requests, trial transcripts, and 

other filings in prominent cases 

• Verdicts and settlements 

Crashworthiness Cases 

[UPDATED September 2006; 1,394 pages] 

• Court documents from three cases, each 

of which addresses one element of 

crashworthiness: rollover crashworthiness, 

door latch defects and frontal crashworthiness 

• Federal Motor Vehicle Safety Standards 

and Regulations 

• NHTSA crash data materials and a list 

of pertinent Internet resources 

• Department of Transportation Notice 

of Proposed Rulemaking regarding roof 

crush resistance 



Firestone Tire Tread Separation 

[August 2000; 929 pages] 

• August 2000; ATX, ATXII, and 

Wilderness AT tire recalls 

• Pleadings and other court documents 

from across the country 

• NHTSA documents 

Interstate Trucking: Independent 

Contractor Defense 

[March 2007; 340 pages] 

• Discussion and guidance regarding how 

to overcome the independent contractor 

defense: statutory employee doctrine 

and nondelegable duty 

• Addresses how to use discovery and 

jury instructions to establish and 

strengthen liability 

• Sample plaintiff motion for partial summary 

judgment and trial brief 

• Internet resources: federal government, 

safety advocacy and research, and 

industry resources 

Interstate Trucking Regulations, 

Discovery and Damages 

[UPDATED December 2006; 1,529 pages] 

• Discussion and guidance regarding the 

hours-of-service-of-drivers, cargo securement, 

and alcohol and drug regulations 

• Sample complaints and discovery requests 

• Deposition of an expert on collision 

warning systems 


• Depositions of management 

information systems personnel regarding 

communication systems 

• Deposition outlines for defense trucking 

and accident reconstruction experts 

• AAJ Education speaker papers on regulations, 

causes of action, accident reconstruction, 

damages, and trial techniques 



Low Speed Impact and Connective 

Tissue Injuries 

[UPDATED May 2007; 940 pages] 

• Key issues in assessing and trying low 

impact connective tissue cases 

• History of Allstate’s Minor Impact Soft 

Tissue (MIST) Program 

• Litigation strategies on voir dire, 

cross-examination of DME’s, whiplash and 

brain injuries, and damages 

• Deposing the plaintiff, defendant driver, 

and biomechanical engineer 

• Court documents and discussion about 

biomechanical engineers and other potential 

defense witnesses 

Preparing a Motor Vehicle Collision Case 


• The initial client interview 

• Potential crashworthiness issues 

• Determining a client’s insurance coverage 

• Working with insurance adjusters 

• Case cost control 

• Motion practice 

• Deposing the defendant driver 

• Handling defense experts, including the 

accident reconstructionist, the biomechanical 

engineer, and the defense medical examiner 

• Selecting a jury 

• The use of demonstrative evidence 

• Arguing damages and 

• Negotiating a settlement 

Nursing Homes 

Discovery Abuse: Lessons Learned 

from Nursing Homes Cases 

[UPDATED March 2006; 676 pages] 

• Sample discovery requests, motions to 

compel, motions for sanctions, and court 

orders in several cases against nursing home 

operators 

• TRIAL articles on discovery abuse 

in nursing home cases and on a wider scope 

• AAJ Education speaker papers outlining strategies 

for overcoming discovery obstruction, 

including discovery abuse in nursing home cases 

• Bibliography of treatises and legal journal articles 

regarding discovery abuse in civil cases 

Nursing Home and Assisted-Living 

Facility Mandatory Arbitration 

[UPDATED January 2007; 412 pages] 

• Analysis of mandatory arbitration 

clauses in nursing-home and assisted-living 

admission contracts 

• Strategies on how to defeat attempts to 

compel arbitration 

• Discovery directed at arbitration clauses 

in admission contracts 

• Sample orders denying defense motions 

to compel arbitration and related briefs 

• Survey of recent case law 

• Bibliography of recent law journal 

and review articles 


Inadequate Staffing 

[June 2004; 2,388 pages] 

• Wrongful death; inadequate staffing 

and documentation; pressure sores, 

malnutrition, and dehydration 

• Key court documents from complaint 

to verdict form 

• Depositions, trial transcript, and trial exhibits 




Lavalis v. Copperas Cove, L.L.C. 

[July 2002; 1,133 pages] 

• Wrongful death case litigated against a 

Texas nursing home 

• Evidence of medical negligence illustrated 

in court documents, including pleadings, 

depositions, expert materials, and 

evidentiary motions 

Nursing Home Litigation: Manor Care 

Management Deposition Collection 

[July 2003; 756 pages] 

• Collection of depositions in a case of wrongful 

death due to inadequate care and supervision 

• Resident bled internally and passed away 

after receiving inadequate care 

• Deponents are the facility’s management 

personnel, including the administrator, 

director of nursing, and other managers 



Nursing Home Litigation: Negligent Hiring 


• Case of negligent hiring, retention, and 

supervision against ManorCare 

• Resident was sexually abused by an employee 

• 30(b)(6) depositions of facility’s administrator 

and human resources director 

• 30(b)(6) depositions of regional human 

resources director and regional director 

of operations 

• Depositions of facility’s director of 

nursing and medical director 



NEW! Nursing Home Litigation: 

Nursing Errors 

[May 2007; 1,022 pages] 

• Explores issues of case investigation, filing, 

pretrial, discovery, and trial 

(continued on following page) 

Summer 2007 

6

• Sample court documents: complaint, interrogatories, 

notice of deposition for corporate 

representative with request for production 

of documents, and depositions 

• Checklists: common defenses, documents, 

and deposition questions for nurse experts 

• Depositions of Administrator, Director of 

Nursing, plaintiff’s nurse expert, treating 

LPN and treating RN 

• Case materials from nursing negligence fall case 

address issues including improper assessment, 

improper care planning, improper charting, 

failure to communicate with physicians and 

violations of the standard of care pursuant to 

OBRA, ANA standards and Nurse Practice Act 


• Secondary resources 



Nursing Home Litigation: Standard of 

Care Expert Deposition Collection 

[UPDATED May 2003; 1,089 pages] 

• Expert depositions in a case of decubitus 

ulcers, malnutrition, and chemical restraint 

• Transcripts for both plaintiff and defense experts 



Pressure Sores 

[December 2006; 1,833 pages] 

• Deposition collection and important 

materials addressing nursing care and 

pressure sore development 

• Depositions of treating physicians and nurses, 

expert geriatricians and registered nurses 

• Cross-examination strategy and questions 

• Pressure sore staging 

• Federal statutes 

• Information on clinical practice guidelines 

• Medical illustration 

• National guidelines summaries 



Premises Liability 

Home Depot USA, Inc.: Falling Merchandise 


• Materials related to incidents of injury 

caused by falling merchandise due to 

improper storage methodsReport of Falling 

Merchandise Incidents (1994–1995) 

• Depositions of Home Depot management 

and loss prevention personnel 



Marriott Inadequate Security 

and Litigation Abuse 

[UPDATED May 2002; 3,116 pages] 

• Inadequate security case in its entirety and 

material from three other Marriott cases 

• Insight from AAJ members about 

inadequate security cases 

Secondhand Smoke Liability 

[May 2002; 542 pages] 

• Outlines a successful landmark Australian 

case brought by a woman who suffered cancer 

as a result of exposure to secondhand smoke 

• Contains noteworthy filings in connection 

with this case, including statements by 

both plaintiff and defense experts, and 

commentary by the AAJ member who 

handled the case 

• Includes Plaintiff ’s Original Statement of 

Claim, Second Defendant Port Kembla RSL’s 

Defense to Amended Statement of Claim, 

Plaintiff ’s Second Further Amended Statement 

of Particulars, Report of Plaintiff’s 

Expert, Transcript of Plaintiff ’s Cross Examination 

of Defense Expert Professor Phillip 

Witorsch, Plaintiff ’s Opening Address, Plaintiff 

’s Closing Address, Judge’s “Summing Up” 

Wal-Mart Stores, Inc.: Falling Merchandise 

[July 2003; 2,454 pages] 

• Plaintiff severely injured by a wall of 

falling merchandise 

• Plaintiff suffered cognitive impairment, 

organic mood disorder, and epilepsy 

• Court documents and depositions 

• Corporate documents, including report 

of falling merchandise (1989-1994) 



Wal-Mart Stores, Inc.: Inadequate Security 

and Litigation Abuse 

[UPDATED October 2003; 1,487 pages] 

• Plaintiff was abducted in the parking lot 

• Plaintiff’s motions for contempt and 

sanctions, and depositions of Wal-Mart’s 

in-house legal team 

• “Smoking gun” corporate documents 

Wal-Mart Stores, Inc.: Premises Liability 

(Shooting) and Litigation Abuse 

[March 2001; 5,292 pages] 

• The Case Record for Robbins v. Wal-Mart, 

including the docket of all the documents 

entered into the record and copies of 113 of 

said document 

• Transcripts and court documents regarding the 

plaintiff’s motions to compel discovery and for 

sanctions for discovery abuses 

• Extensive discovery material from Robbins 

and other cases, including Wal-Mart’ 

produced documents and depositions of 

key Wal-Mart employees 

Wal-Mart Stores, Inc.: Slip and Fall 

[October 2002; 1,444 pages] 

• Documents from a case in which Wal-Mart acted 

negligently in failing to adhere to its policies 

• Internal documents outlining store policies 

Products Liability 

Bed Rails: Dangerous Devices 


• Profiles two wrongful death actions where the 

decedents were killed as a result of bed rail 


entrapment: one death occurring at a hospital 

and the other death occurring at a long-term 

care facility 

• Focuses on the physical apparatus of bed 

rails, the bed manufacturer’s responsibility for 

design, and related products liability issues 

• Depositions of key bed manufacturer employees 

including: Director of Regulatory Affairs, 

Design Engineer, Account Executive, and 

Field Representative 

• Motion for judgment in an entrapment case, 

similar matters and a case abstract 

• Westlaw Survey regarding Company Profiles for 

the three largest bed rail manufacturers 

• FDA materials including safety alert, bed safety 

guide, and clinical guidance assessment 



Heart Device Recalls 

[UPDATED February 2007; 639 pages] 

• Thousands of defibrillators and 

pacemakers recalled 

• Sample client intake and questionnaire 

• Timeline of key events and similar matters 

• Guidant and Medtronic complaints, motions, 

a preservation order, and MDL information 

• Statute of Limitations issues and federal 

preemption case law and statutes 

• Order denying Medtronic’s motion for 

summary judgment based on preemption 

• Information on Guidant bellwether trials and 

Medtronic and Guidant bundling orders 

• Information on the Independent Panel of 

Guidant Corporation investigation 

Tasers: Unsafe and Lethal 

[May 2006; 569 pages] 

• Complaints from two separate 

Taser cases (one alleging wrongful death 

and the other alleging use of excessive 

force and civil rights violations) 

• Depositions from key Taser International 

employees, including the Vice President 

of Research and Development, Director 

of Training, Director of Technical 

Programs, and a Regional Manager 

• Taser study from the American Civil 

Liberties Union of Northern California 



Medical Negligence 

NEW! Birth Injury Cases: Shoulder 

Dystocia Expert Deposition Collection 

[July 2007; 250 pages] 

• Collection of depositions in a case 

involving a breech birth and shoulder 

dystocia presentation 

• Injured infant diagnosed with brachial 

plexus injury and Erb’s palsy 

• Deponents include experts in Obstetrics 

and Gynecology, Perinatology, Physical 

Medicine and Rehabilitation, Pediatric 

Neurosurgery, and Life Expectancy 



Birth Injury Cases: Shoulder Dystocia 

[UPDATED August 2006; 1,753 pages] 

• Deposition testimony of plaintiff and defense 

expert witnesses regarding brachial plexus 

injury sustained by infant after diagnosis 

of shoulder dystocia 

• Complaint detailing defendant’s negligence 

in prevention of further fetal injury 

• National guidelines regarding shoulder 

dystocia and childbirth procedures 



Failure to Diagnose Breast Cancer 


• Explores complex issues of causation, 

standards of care, loss of chance for a cure, 

staging, life expectancy, and overall case 

handling strategies and techniques 

• Case snapshot including the complaint 

and depositions of seven physicians and 

two nurse practitioners 

• Materials from other cases including 

complaints, plaintiff requests for production, 

plaintiff interrogatories, and depositions 



Failure to Diagnose a Pulmonary Embolism 

[April 2005; 866 pages] 

• Complaint detailing defendant doctor’s, 

defendant hospital’s and defendant 

physician group’s negligence in 

diagnosing a pulmonary embolism 

• Deposition of defendant doctor regarding 

ER standard of care for detection of a 

pulmonary embolism 

• Depositions of Medical Review Panel witnesses 

regarding deviation from standard of care 

• Depositions from expert plaintiff and 

defense witnesses regarding adequacy 

of treatment rendered 

• Depositions of plaintiff and defense 

administrative experts regarding hospital 

policy and procedure 

• National guideline regarding evaluation 

and management of a pulmonary embolism 



Fetal Distress Signs and Failure 

to Timely Perform a Cesarean Section 


• Case profile 

• Complaint 

• Opening Statement 


expert witnesses 

• Closing Statement 

• Verdict information 

• National guidelines regarding fetal distress, 

induction of labor, c-sections, and preclampsia 



Summer 2007 

8

Hospital-Acquired Infections 


• Explores patient safety and infection control 

procedures in the hospital setting 

• Sample complaints in hospital-acquired 

surgical infection and meningitis cases 

• Discovery request and expert disclosures 

• Verdict information and petition for appeal 

regarding damages cap 

• Depositions and summaries of defense 

witnesses in a hospital acquired infection case 

• Summaries of national guidelines 



Injured Infants: Failure to Diagnose Meningitis 


• Profiles the case of a newborn infant who 

contracted a hospital acquired infection 

that caused meningitis 

• Complaint outlining liability for 

all defendants 

• Depositions of the mother and father who 

discuss daily living activities and quality 

of life issues 

• Depositions of the treating pediatrician, 

neonatologist, and nurse practitioners 


expert witnesses 

• National guideline summaries regarding 

meningitis diagnosis and proper management 

of a febrile infant 



Laparoscopy: Minimally-Invasive 

Abdominal Surgery 

[UPDATED August 2006; 1,547 pages] 

• Court documents and depositions 

• FDA report on laparoscopic trocar injuries 

• Glossary of medical terms and a medical 

literature bibliography 

• Consensus statements and clinical 

practice guideline summaries 

• Medical illustration and a Medifocus 

Reference Guide from AAJ Extras program 

members Medical Legal Art’s Doe Report and 

Medifocus Legal 

LASIK 


• Outlines the risks resulting from improper 

screening, surgeon error, equipment 

malfunction, lack of informed consent, 

and postoperative complications 

• Court documents (complaint and request for 

production of documents) 

• Depositions of defendant-ophthalmologists, 

defendant-optometrists, and a defense 

ophthalmologist expert 

• Trial transcript and summary of a plaintiff’s 

vision scientist expert 



Life Expectancy and Neurological Injury: 

Defense Experts 

[UPDATED March 2006; 1,018 pages] 

• How to persuade the court to exclude 

these defense experts’ testimony 

under Daubert 

• Plaintiff and defense motions and 

memoranda, depositions, trial testimony, 

and favorable court orders 

Litigating Gastric Bypass Cases 

{UPDATED May 2005; 1,752 pages} 

• Court documents 

• Depositions 

• Deposition outline for a bariatric surgeon 

• Medical illustrations and literature survey 

• Consensus statements 

• Clinical practice guideline summaries 



NEW! Medication Errors 

[August 2007; 1,400 pages] 

• Explores issues of investigation, filing, pretrial, 

discovery and trial 

• Sample court documents: complaint, requests 

for admission, interrogatories, requests for 

production and depositions of both treating 

and expert doctors and nurses 

• Case materials from two medication error 

cases—a post-surgical medication error in 

the hospital setting and a post-automobile 

accident emergency services medication 

error in a helicopter 




Nursing Errors in Hospitals 

[March 2007; 1,624 pages} 

• Explores issues of case investigation, filing 

and pretrial, discovery, trial and post-trial, 

including hospital liability, physician liability, 

res ipsa loquitur, and standard of care 

• Sample court documents: complaint, interrogatories, 

requests for admissions, requests 

for production, and appellate briefs 

• Checklists: common defenses, 

documents,and deposition questions for 

nurses and nurse experts 

• Depositions of treating nurse, nurse supervisor, 

nurse expert and Chief Nursing Officer. 

Trial testimony of treating nurse, nurse expert 

and treating doctor 

• Case materials address issues of failure to 

monitor, improper performance of treatment, 

negligent administration of medication, and 

failure to communicate 



Pharmacy and Pharmacist Liability 

[UPDATED April 2006; 290 pages] 

• Discussion of traditional pharmacy and pharmacist 

liability, and the trend of broadening liability 

• Court documents from cases involving the 

failure to dispense the proper medication 


and the failure to warn of contraindication 

between two medications 

• Depositions of plaintiffs’ pharmacy and 

toxicology experts from a “misfill” case 



Surgical Negligence: Retained Towel 

[September 2006; 764 pages] 

• Key documents that focus on surgical and 

nursing standards of care regarding surgical 

count procedures and causation 

• Complaint and timeline of events 

• Plaintiff and defense motions for summary 

judgment and reply memoranda 

• Jury instructions on foreign object 

counting and res ipsa loquitur 

• Plaintiff’s closing argument transcript 

• Depositions of several defense and 

plaintiff expert witnesses 



Toxic and Pharmaceutical Torts 

Bausch & Lomb 


• ReNu with MoistureLoc, a contact 

lens cleaning solution, linked to 

outbreak of Fusarium Keratitis 

• Client intake form and questionnaire 

• Complaint 

• Information on Fusarium Keratitis 

• Timeline of key events 

• AAJ Education speaker papers and 

similar matters 

• Medical journal survey and illustrations 

Bextra 


• Sample complaints and client intake form 

• Similar matters from the Exchange database 

• Multi-district litigation information 

• FDA regulatory information and materials 

• Clinical study results 

Fen-Phen 


• Developments regarding the weight loss 

regimen known as “Fen-Phen” 

Fosamax, Zometa and 

Other Bisphosphonates 

[April, 2007; 289 pages] 

• Provides overview of Fosamax, Zometa and other 

bisphosphonates and the emerging litigation 

concerning their link to osteonecrosis of the jaw 

• Information on case screening, including 

sample client questionnaire 

• Sample complaint and court orders 

• Information on osteonecrosis of the jaw (ONJ) 

• Timeline of key events with links to 

key documents 

• Resources regarding FDA preemption 


• Similar Matters 

• Secondary resources including Internet resources 

and bibliography of medical journals 

• Medical illustrations from Medical Legal Art: 

The Doe Report, an AAJ Extras provider 

Hormone Therapy Litigation Packet 


• Women’s Health Initiative Estrogen Plus 

Progestin Study (WHI) confirmed 

suspicions that serious risks were associated 

with hormone therapy 

• Sample client intake form and questionnaire 

• Sample complaint 

• Sample requests for production 

and interrogatories 

• MDL information 

• Preemption materials 



Kugel Mesh Litigation Packet 

[April 2007; 137 Pages] 

• Composix® Kugel Mesh hernia patch, 

manufactured by Davol Inc., is subject 

to a Class I recall by the Food and Drug 

Administration (FDA) 

• More than 100,000 units recalled 

• Overview of litigation status 

• Case screening materials, including client intake, 

questionnaire, and sample operative reports 

• Court documents including sample 

complaint; class action complaint; and 

Defendant’s interrogatories 



• FDA Materials 

• Medical journal survey and illustrations 

Lead Paint Litigation: Landlord 

and Manufacturer Liability 

[UPDATED September 2005; 1,120 pages] 

• Case of a Missouri child who contracted severe 

lead poisoning as a result of living in apartments 

treated with lead-based paint 

• Illustrates how to handle cases of injury caused 

by lead paint poisoning and lead paint hazards 

• Discussion of the litigation against 

manufacturers, distributors and promoters 

of lead pigments and lead-based paint 

Lotronex 


• Case evaluation information, court 

documents, and depositions of treating 

and clinical trials physicians 

• FDA materials and corporate materials 

Methyl Tert-Butyl Ether (MTBE) 

[UPDATED January 2005; 1,012 pages] 

• Court and EPA documents 

• News and information on lawsuits 

and legislation 

Summer 2007 

10

Ortho Evra 


• New labeling warns of increased exposure 

to higher dose of estrogen than birth 

control pills 

• Client questionnaire and complaints for 

wrongful death, pulmonary embolism, 

stroke and heart attack 

• Information on federal and state litigation 

• FDA materials regarding product approval, 

labeling changes, and adverse events 

• Timeline of key events 

• Preemption materials 



• Medical glossary, journal survey, 

and illustrations 

Pharmaceutical Products Liability Cases 


• Drug companies’ direct-to-consumer 

marketing tactics and the effect on the 

learned intermediary doctrine 

• Promotion of off-label use by drug 

companies, and the adverse effects 

• Pharmacology, epidemiology and its 

role in proving causation 

• Theories of liability and recent trends 

• Sample complaints, client intake forms, and 

drug intake and evaluation forms 

• Selecting and “Daubert-proofing” your expert 

• Materials on the new FDA rule 

affecting preemption 

• Strategies, briefs, orders, and case law on 

avoiding preemption 

• Sample requests for production and interrogatories; 

sample 30(b)(6) questions for the 

drug’s company’s PMK about drug safety and 

others; sample deposition questions for the 

pharmaceutical detailer 

• Obtaining electronically-maintained 

information in discovery, and an explanation 

of the Adverse Event Reporting System 

Rezulin 


• Court documents 

• News on expert testimony, class 

actions, and more 

Selective Serotonin Reuptake Inhibitors 

(SSRIs) and the Link to Suicide 


• Court documents (sample complaints, 

interrogatories, requests for production 

of documents, opposition to a motion for 

summary judgment on grounds of federal 

preemption and memorandum opinion) 

• Case abstracts and similar matters from 

the Exchange databases and Westlaw 

• AAJ Extras member Medifocus Guide 

• An open-access article from PLoS Medicine 


TRIAL articles 

• FDA Resources and Survey of news articles 

• Internet resources 

Toxic Mold 

[UPDATED January 2006; 1,514 pages] 

• Court documents, including sample 

complaints and discovery requests against 

a variety of defendants 

• Tips on selecting your expert, proving causation, 

and handling the Daubert challenge 

• Discussion of potential defendants and 

causes of action 

• Key paper about proving neurotoxic 

and cognitive injuries using Daubert, 

epidemiological studies, ACOEM paper, 

and National Academy of Science report 

• CDC reports on state of the science on 

molds and human health, including recentlyreleased 

report on possible health effects in 

the aftermath of Hurricanes Katrina and Rita 

Vioxx 


• Sample documents including client intake forms 

• Similar matters from the Exchange database 

Vioxx Update 


• Federal and state litigation updates 

• Vioxx and Ernst fact sheets from AAJ’s 

Communications Department 

• Court documents (sample client intake 

form, sample federal complaints, federal 

jury charge and interrogatories, state class 

action complaint, remand motions, and 

court orders and opinions) 

• FDA’s Sequence of Events with Vioxx 

(1994 IND to 2004 Withdrawal) and David 

Graham’s memo 

• Analysis of internal Merck marketing 

documents from House of Representative 

hearing and Senate hearing testimony 


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