Sample Pretrial Statement

THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND

NATASHA BEVENS
- Plaintiff

v

SEA SYSTEMS
- Defendant

CASE NO. 0702-0000000-2011

Plaintiff, Natasha Bevens, by and through her attorneys, Laura G. Zois and Miller & Zois, LLC, offers this Honorable Court Plaintiff’s Pretrial Statement in the above-referenced matter.

Plaintiff Bevens was employed as a building service worker at Holabird Middle School. She was working the night shift and during the morning hours of October 27, 2012 the school lost power, the lights went out, and an alarm began to sound. Plaintiff Bevens called her supervisor and was directed to the electrical room to silence the alarm. As she entered into the electrical room it was dark. As Plaintiff Bevens started to cross over the floor of the electrical room and walked towards the alarm panel, she fell into an uncovered hole of the floor.

Defendant Sea Systems, Inc. was working in the electrical room the day before Plaintiff Bevens’s fall and failed to cover a hole in the floor. Defendant Sea Systems, Inc. was negligent for failing to properly secure the floor of the electrical room.

Plaintiff Bevens suffered from serious and permanent injuries. She suffered from a complex open right ankle fracture, and dislocation which required surgery with hardware. She has permanent nerve damage to her ankle and foot which will require her to be on pain management for the rest of her life. Plaintiff Bevens is 38-years-old and has a life expectancy of 43.6 years.

None.

None.

Plaintiff has served the Defendant with Requests for Admissions which could simplify some of the issues in the case, however, Defendant has not yet responded to the Requests.

Plaintiff claims the following special damages to date:

Plaintiff reserves the right to make a claim for non-economic damages for pain and suffering incurred in the past, and pain and suffering that is reasonably expected to be incurred into the future. Plaintiff also intends to present evidence of the need for future medical treatment including, but not limited to, pain management office visits 3 times per year, and orthopaedic consults at least once per year. Additionally, she must maintain her current medication regime including Fentanyl patches every three days, Endocet three times a day, Pregabalin twice a day, and Quinine once a day. Her annual medical expenses per year are $6,180.27 and her future medical expenses, based on her life expectancy of 43.6 more years, total $269,459.77.

1. Medical Records and Bills of the Plaintiff;
2. A Summary of Plaintiff’s Medical Specials;
3. Defendant Sea System’s Answers to Interrogatories;
4. Incident Report;
5. Deposition Transcript of Witness Warren Bright;
6. Deposition Transcript of Witness John Damron;
7. Deposition Transcript of Witness Mark Robinson;
8. Deposition Transcript of Andrew Kinman;
9. Deposition Transcript of Averell Reinhart;
10. Deposition Transcript of Scott Snyder;
11. Photographs of the area where the incident took place;
12. Demonstrative video of the Plaintiff’s surgical procedure;
13. Demonstrative anatomical exhibits of Plaintiff’s ankle;
14. Radiological Imaging of Plaintiff’s ankle;
15. Life table of the Plaintiff;
16. Documents produced by Defendant;
17. Relevant portions of authoritative sources relied up by experts;
18. Diagram of the electrical room; and

Plaintiff reserves the right to introduce any documents exchanged during the course of discovery that are not specifically identified above.

1. Plaintiff, Rachel Bevens;
2. Defendant, Sea System’s Inc corporate representative;
3. Witness, Mark Robinson;
4. Witness, John Damon;
5. Witness, John Dunst;
6. Defendant Employee, Andrew Linman;
7. Defendant Employee, Averell Meinhart;
8. Defendant Employee, Steve Snyder;
9. Margaret Bevens;
10. Dennis Bevens;
11. Barbara Williams;
12. Mary Wood.

Plaintiff reserves the right to call any witnesses identified by either party during the course of discovery not listed above.

1. Dr. LeBron Wade, Johns Hopkins Bayview Medical Center, 4940 Eastern Avenue, Baltimore, Maryland 21124, is an expert in the field of emergency medicine and general surgery and orthopaedic surgery;
2. Dr. Kobe Gasol, John Hopkins Bayview Medical Center, 4940 Eastern Avenue, Baltimore, Maryland 21224, is an expert in the field of general medicine, rehabilitation, and pain management; and
3. Kevin Westbrook, CSP, P.E., SPA, inc., 203 West 11th Avenue, Baltimore, Maryland 21225, 410-789-5858, is an expert in the field of Workplace Safety and Human Factors.

Respectfully submitted,
Miller & Zois, LLC

Laura G. Zois
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
Attorney for the Plaintiff

I, Laura G. Zois, do hereby certify that I a copy of Plaintiff’s foregoing Pretrial Statement was hand delivered on this 17th day of July, 2013, to:

Franklin & Prokopik
Two North Charles Street, Suite 600
Baltimore, Maryland 21201
Attorneys for Defendant

Laura G. Zois

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