reach three
TRANSCRIPT
Tell your story through a
timeline(continue to left click for slide transitions)
Jane Doe meets her friend Linda Grey along with Grey’s Mother and Sister at Cantina Laredo for Dinner and Cocktails. Doe consumes red wine.
6:00PM
PRE INCIDENT FACTS SURROUNDING THE ACITIVITES OF JANE DOE
EVENING OFJUNE 26, 2009*
*Source: Linda Grey audio interview conducted by Officer Gellina on 07-10-09
Jane Doe meets her friend Linda Grey along with Grey’s Mother and Sister at Cantina Laredo for Dinner and Cocktails. Doe consumes red wine.
6:00PM
8:30Doe and Grey depart Cantina Laredo and head to New York Grill for dancing and cocktails. Grey’s Mother and Sister meet them there. Doe purchases a round of drinks
PRE INCIDENT FACTS SURROUNDING THE ACITIVITES OF JANE DOE
EVENING OFJUNE 26, 2009*
*Source: Linda Grey audio interview conducted by Officer Gellina on 07-10-09
Jane Doe meets her friend Linda Grey along with Grey’s Mother and Sister at Cantina Laredo for Dinner and Cocktails. Doe consumes red wine.
Doe and Grey depart New York Grill and head to Ouzo Blue Tavern for Ouzo shots while Grey’s mother and sistercall it a night
6:00PM
10:00
8:30Doe and Grey depart Cantina Laredo and head to New York Grill for dancing and cocktails. Grey’s Mother and Sister meet them there. Doe purchases a round of drinks
PRE INCIDENT FACTS SURROUNDING THE ACITIVITES OF JANE DOE
EVENING OFJUNE 26, 2009*
*Source: Linda Grey audio interview conducted by Officer Gellina on 07-10-09
Make your point by
emphasizing critical
distinctions in the law
440.02(3)(c)
“Employee” Includes:An independent
contractor working or performing services in
the construction industry
440.02(3)(c)
“Employee” Includes:An independent
contractor working or performing services in
the construction industry
440.02(3)(c)
440.02(3)(d)(1)
“Employee” Includes:An independent
contractor working or performing services in
the construction industry
“Employee” does not include: An independent
contractor who is not engaged in the
construction industry
440.02(3)(c)
440.02(3)(d)(1)
LIABILITY UNDER VERTICAL IMMUNITYACME
CONSTRUCTION
Plaintiff must prove by “clear and convincing” evidence that the employer deliberately intended to injure the employee;
or that the employer engaged in conduct that the employer knew based on prior similar accidents or explicit warnings identifying a known danger was virtually certain to result in injury and death, and;That the employee was unaware of the risk because the danger was not apparent and the employer deliberately concealed or misrepresented the danger so as to prevent the employee from exercising his informed judgment regarding performance of the work.
Emphasize positive findings
OSHA INVESTIGATION
OSHA INVESTIGATION
REFLECTIVE VESTS
OSHA INVESTIGATION
REFLECTIVE VESTSASSIGNED WORK ZONE TRAFFIC CONTROLLER
OSHA INVESTIGATION
REFLECTIVE VESTSASSIGNED WORK ZONE TRAFFIC CONTROLLERDAILY INSPECTIONS
OSHA INVESTIGATION
REFLECTIVE VESTSASSIGNED WORK ZONE TRAFFIC CONTROLLERDAILY INSPECTIONSADEQUATE WORK ZONE
Highlight important passages
Point out significant injuries
Torn rightRotator cuff
Torn rightRotator cuff
Bruised ribs
Torn rightRotator cuff
Bruised ribs
FracturedLeft
patella
Highlight important
deposition testimony
P. 7, L. 7-10
Q. Was there any discussion on the jobsite that standing water might cause a hazard to people that weredriving through it?
A. Yes.
Deliver your message
Clearly