Sample Personal Injury
Trial Materials
- Personal Injury Auto Accident (pattern jury instructions and selected non-pattern instructions in personal injury auto accident and medical malpractice cases)
- Defendant's Requested Voir Dire in Auto Accident Case (sample of voir dire sought by the defendant's attorney in a personal injury auto accident case)
- Wrongful Death Survival Action (sample outline of an opening statement in a Maryland wrongful death products' liability case)
- Sample Transcript: Direct/Cross of Plaintiff's Treating Doctor (ankle fracture and soft tissue injury case)
- Sample Transcript: Direct/Cross of Plaintiff's Treating Doctor (herniated disc and soft tissue injury case)
- Personal Injury Accident Victim (outline of a direct examination of a gentleman who was crushed by a Bobcat backhoe)
- Personal Injury Accident Victim's Treating Doctor (outline of direct examination in personal injury auto accident case involving a femur fracture and cracked ribs)
- Personal Injury Auto Accident Victim's Wife (outline of the spouse of the injury victim in an automobile accident case)
- Personal Injury Accident Victim's Doctor #2 (outline of treating doctor ACL tear and herniated disc case)
- Medical Doctor in Wrongful Death Survival Action (pain and suffering witness in wrongful death/survival action case where decedent was burned to death)
- Direct Examination of Accident Reconstructionist (outline of reconstructionist in wrongful death case where expert claimed speed and alcohol were contributing causes of the accident
- Sample Transcript: Direct/Cross of Defendant's Medical Doctor Expert (Kevin F. Hanley, M.D. in a knee surgery case in Anne Arundel County)
- Sample Transcript: Direct/Cross of Defendant's Medical Doctor Expert #2 (defendant's doctor in an ankle fracture and soft tissue injury case in Prince George's County)
- Sample Transcript: Direct/Cross of Defendant's Medical Doctor Expert #3 (defendant's doctor in herniated disc and soft tissue injury case in Howard County)
- Sample Transcript: Direct/Cross Defendant's Medical Doctor Expert #4 (Dr. Robert O. Gordon in Prince George's County personal injury auto accident case)
- Defendant Driver (outline of defendant driver in an auto accident in Baltimore City)
- Defense Medical Exam Doctor (outline cross examination from a presentation given on cross examination of the defendant's medical doctor)
- Maryland Auto Accident Pattern Instructions
- Jury Instructions (sought by defendant in a personal injury auto accident case)
Non-pattern Jury Instructions with Analysis
- Reasonable and Prudent Speed Required
- Unavoidable Accident
- Driving on Divided Highways
- Passing on the Right
- Driver to Control Speed
- Approaching and Going Around Curves
- Approaching Crests of Grades
- Traveling on Narrow or Winding Roadways
- Special Dangers as to Pedestrians or Other Traffic
- Negligent Driving
- Presumption of Negligence in Rear-End Accident (based on Maryland case law that creates a rebuttable presumption that the rear ending driver is at fault in a rear end auto or truck accident case)
This attorney trial help page is a recent addition to the Miller & Zois Maryland personal injury lawyer help center. A number of lawyers in Maryland and from other jurisdictions have told us that being able to review some of these sample transcripts and outlines have been helpful to them in preparing their case for trial. We will keep adding to this trial area in the coming months. If you have trial materials you believe would be of assistnace to our readers, let us know and we will be glad include them.
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