Perhaps that’s a better way of doing it perhaps it’s a way of making your point that much more clear so let me give you a case right this case down I don’t give you too many sites but the ones I do are important this is a case by the name of Karen Lynn versus the city of New York it’s a case that Bob Colonist happened to try Appellate Division that’s Appellate.
Division New York sub-second it’s a it’s a second apartment case that’s if I could read a , it says this unify trial liability of damage and damages is appropriate where the injuries have an important bearing on the liability itself so if the injuries have an important bearing on liability you can make the motion you make the motion hopefully so that you get the unify trial granted and guess what you can often get a much better result by doing that it means a little bit more work on your part because you have to evaluate the medicals well as luck would turn out there or there are always three.
Guys in Brooklyn that I saw all the time when I used to try cases there regularly I don’t try them regularly anymore in Brooklyn but I will tell you the lawyers worse – barely there was normally Heller and there was another guy named Walter back for those of you who remember this one happened to be against Walter Beck Walter’s a fine lawyer and I will tell you he opposed the motion we won the motion we were able to show that in fact the injuries did have an important bearing on liability.
so let me give lawyer for wrongful death you the opening statement you’ll see the way that I dealt with this for the jurors to see what happened ladies and gentlemen on June a woman was injured she was injured severely and she was injured because a driver failed to keep a reasonable and proper lookout and because that same driver failed to use that degree of care that he should have when he was making.
A right-hand turn at an intersection in fact as a result of the failures on the part of that driver as a result of the carelessness as a result of the negligence on the part of that driver this woman has been injured and she has been injured severely so much so that the injuries #FaceBook will be with her for the rest of her life the woman that was injured is my client Doris Dana who happens to be right.