How Witnesses Can Tell the Whole Story to the Jury on the Impact of a Personal Injury

There’s an industry term I use called ‘Before and After.’ I’ll say to my paralegal “Do we have the before and afters disclosed yet?” What I mean is have we identified and verified that we have people in my client’s life that we’ve contacted and verified that they knew my client before and after the incident I represent them on. Second, can they testify to the changes they’ve seen in my client’s life?

Just as it is important for me to have medically documented symptoms for my clients it’s often more important for me to have these ‘Before and Afters’ that can testify to how my client’s life has changed due to the incident in question. This helps paint a picture to a jury of not only what is going on but also how it affects their daily living.  For example a DTI can show brain damage but a teacher of my client can say what he sees, for example falling grades. Or a client of mine used to play basketball every weekend with his buddies and his friends don’t see him at all anymore. Or a client of mine used to welcome people at her church but can’t stand for long periods anymore. Or a father can’t play catch anymore with his son.

These stories coming from people who know my client is vital testimony to translate the doctor’s stacks of medical records into real world impacts. That’s why I always try to include these ‘Before and Afters’ in every case I file.