“This trial was a TLC trial if there ever was one. I did the listening exercise, doubling, all the psychodrama methods I learned, and we were able to reenact the crash during cross-examination. I asked for over a million dollars in a conservative county in Michigan and before trial even started I had people laughing and telling me I had a frivolous case, including some of the people on the jury in the venire.” – Dominic Andriacchi Jr. (TLC2 ’17)
Dominic Andriacchi Jr. graduated from TLC’s 3-Week Flagship College in September 2017 and has since taken a new approach to fight for the clients he represents. Dominic graduated from law school in 2012 and moved back to where he grew up in Northern Michigan to join his father at their partnered law firm. Before attending TLC’s 3-Week College, Dominic had two jury trials: a child protection case and a criminal case. Since graduating, he has taken 7 cases to trial and believes his trial work accomplishments come straight from what he has learned at TLC. “There’s an organization for criminal defense lawyers in Michigan that have a few TLC faculty: Cheryl Carpenter, Keeley Blanchard, Marj Russell, and sometimes Josh Karton. They often mentioned TLC, and I asked them about it. That’s when I looked online and found the Trial Lawyers College, and the following year I applied to the 3-Week College.”
Dominic took on his first personal injury case against a trucking company and used everything he learned at TLC to bring a deserving reward to his injured client and her family. Dominic was initially worried about bringing such a big case to a small conservative Midwestern town but knew it was important to fight for his wronged client who was dealing with prolonged medical conditions that continued to get worse. He also had a personal relationship with his client; he went to high school with their son years ago. “I spent a lot of time with them and genuinely love both of them. I represented the wife, but the husband comes with the wife and I wanted to do the best I could for both of them. I learned a ton of small vignettes to use in trial from just spending time with them. For example, I spent 5 hours on father’s day just sitting at their table drinking coffee and talking.”
When his client walked into their office ready to bring their case, Dominic had never delved into PI waters, so he was also taking a new leap into unknown territory. He had to do his research and work with his client’s medical providers to learn more about her injuries to bring a strong case to trial. “I want to do criminal defense and handle personal injury cases because I am interested in car crashes, traumatic brain injuries, etc. I play sports so I know about concussions, but never really put two and two together until I had this case. So, I’ll continue to work on personal injury and criminal defense cases.”
During Dominic’s voir dire, he remembers telling the jurors that they were looking for a million dollars or more in Northern Michigan, where the average person makes forty thousand dollars per year, but he made sure to provide an open and honest place for the jury so by the end of trial, they could deliver that kind of verdict. “My biggest problems were handling the gap in treatment and that for the first year she didn’t report many symptoms. I covered that in jury selection and opening to suck the wind out of the defense’s sails. I also called in 10 lay witnesses: neighbors, co-workers, etc. who all vouched for my client’s injuries. I went on to say that if they wanted to look at the medical records and find that she’s a liar, they could, but that medical records (pieces of paper) are not her life, that a human being is more than pieces of paper and they should listen to medical providers, friends, and family instead.” Dominic felt like the defense looked for every excuse to blame his client instead of accepting responsibility and agreeing to be held accountable for their driver’s actions. Dominic cross-examined their defense doctor and had previously practiced this at TLC event, so when it came to this point in trial, he felt confident. “I had the jury literally laughing at this guy because I was polite and I did everything they teach at TLC, but the guy just came across as so unbelievable.” During trial, Dominic refrained from objecting, but when he started questioning the truck driver that caused the accident, the defense lawyer raised objection after objection. “I said to the jury in closing that it was like the elementary school kid who hits another kid, then runs to the teacher. That way the other kid doesn’t get a chance to fight back. This resonated with the jurors.”
Dominic felt a good connection with the judge in this particular case. “He didn’t really tell me I couldn’t do anything. There were no objections to the voir dire, no objections to my opening, my closing, and no objections to the reenactments or how I had the witness come out of the witness box. I think the judge liked it. About halfway through, I told him that I was at TLC and he started asking about it. I think he wanted to see for himself what TLC teaches, and it felt like he gave me maybe a little bit more free range to do what I needed to do.”
The defense’s highest offer was $50,000; three local attorneys evaluated the case’s worth at $10,000. Dominic made three separate offers to settle at the policy limit of $1,000,000, including one a week before trial. They told Dominic that it was a conservative area and no one would understand his client’s injuries, but after using the TLC methods and bringing a powerful case to trial, the jurors deliberated for 3 hours and came back with the $1.2 million verdict.
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