Hi, I’m Tony Castelli, a Cincinnati personal injury trial attorney, and today my message is about what we do in trial.  And it’s just a very small piece, but it’s something that I like to do.

I like to use a nice, large exhibit of my client’s injury, especially if they have had some type of surgery.  The reason for this is it focuses the jury’s attention on the injury.  It helps explain the injury.  When you ask the doctor, “Doctor, what did you do in surgery,” and he gives you five-second answer and it blows by everybody, you can slow him down and say, “Wait a second, doctor.  I’d like you to look at this exhibit, say, of a shoulder surgery, and here’s what they looked like before.  Now, tell me what you did here.  And what's that part of the body there, and what is that tool that you used there?”

I’ve used these exhibits successfully in shoulder injury cases.  I’ve used them in hip replacement cases.  I’ve used them in knee replacement cases.  And, invariably, what happens once it’s introduced, it’ll sit there in the courtroom and I always let it face the jury.  And if nobody says anything, every time the jury walks in, they see that exhibit.  There's that exhibit.

And another exhibit that you can use besides an indication of their injury is if there's some severe and significant car damage.  I’ll blow up a photograph gigantic, and, you know, those two pieces of evidence, they say a pictures worth a thousand words, well, a picture is worth a thousand words and an exhibit is worth a thousand words and it can only serve to help get my clients more compensation.  

So that's one of the techniques I use in a jury trial.  

Thanks a lot.  Have a great day.