"Since embracing TLC methods over the past few years, my last five jury trials have resulted in seven-figure verdicts. I know a lot of my success is from TLC; I have learned to be a better listener which leads to being a better storyteller. It’s all about the details. You have to really go deep to find those special little details to make these stories memorable and impactful in the courtroom. TLC provides great tools to find those special diamonds." - Lloyd Bell, '16 September Graduate

TLC's methods are an integral part of Lloyd's trial preparation. What he does more now than he ever has before is find the time to spend with his client in their homes and with their family members to build genuine relationships. He focuses on re-enactments using auxiliaries to 'Discover their Stories'. Lloyd describes this as a critical part of trial preparation: “Even if you’re thinking about 15 other things you’d rather be doing, spending time on the 'soft parts' of the case – visiting my clients, discussing their family photos - is incredibly important to develop an authentic connection with my clients."

A powerful preparation technique Lloyd now uses in his cases is to have his client collect as many photographs as they can, within reason, over the course of their lifetime. He spends time with his clients discussing and understanding the stories behind the photos. Lloyd says he also uses psychodrama techniques like Chair-Back and Intense Focused Listening, to understand the more nuanced parts of the story that provide the deeper details, more-so, to provide the finishing touches of the real story.

Medical Malpractice Trial

"I think the most shocking aspect of this case, other than the underlying malpractice, is the fact the defense ever let this case go before a jury. The insurance company decided to gamble and the trial ended up being a 'perfect storm' of poor choices on the defense side. They had no idea the power we were ready to unleash in trial from our preparation with the TLC methods and our strong visual strategy."

Lloyd represented 55-year-old Sandy Williams who had an elective ACDF (Anterior Cervical Discectomy Fusion) neck surgery to help with chronic neck pain. Sandy experienced progressively worsening problems swallowing after she was discharged home. Two days after discharge, Sandy’s husband called the on-call neck surgeon and explained the problems Sandy was having swallowing. The on-call doctor advised Sandy to suck on a popsicle and go to the ER in the morning if the symptoms did not resolve. After hanging up the phone Sandy and her husband decided to go on to the ER. The ER doctor ordered x-rays which showed a large mass in Sandy’s neck, what was determined to be a cervical hematoma or large blood clot. The ER doctor reported back to the on-call doctor, but the on-call did not come in to see Sandy for over 6 and ½ hours. By the time he got to Sandy’s bedside, her ability to breath had deteriorated.

At this point, Sandy started turning blue because her oxygen levels had dipped down into the 30% range. About a half hour later, the on-call anesthesiologist arrived to see the mess Sandy was in; unconscious, blue, and unable to breathe. After close to 20 minutes at this level, the anesthesiologist was finally able to intubate Sandy and restore her breathing. Sandy woke up ten days later with a profound brain injury; she was blind, unable to walk, and unable to speak clearly.

TLC Methods Motivated Jurors

"During trial, a TLC technique I used repeatedly was re-enactment. I’m a huge believer in re- enactment and fully embrace it. I started using this tool in my Opening Statement when I incorporated a physical re-enactment to help bring the story alive."

Lloyd’s team used physical demonstratives like a red water balloon to represent the hematoma which provided a physical anchor throughout the trial. The red balloon could easily be picked up and placed next to the neck to show the size and location of the hematoma. During Lloyd's cross-examination, he re-created the physical space of the ICU room and defined the boundaries of the head and foot of the bed, the door, the tables, etc. “This was helpful to the jury because there were a lot of areas of possible confusion as to how exactly Sandy suffered her injury and the actions of the healthcare professionals during the moment of respiratory collapse. Bringing the room to life helped the jury understand the incident in a much more tangible way,” Bell explained.

"The most impactful TLC moment that will stay with me forever, was during Closing Argument. I engaged the jury in discussion about Sandy’s losses and what they truly meant. Probably the biggest loss to Sandy was her blindness that kept her from seeing her new grandchild. As I was standing there near the jury and discussing this loss, I looked over at Sandy in her wheelchair. Quiet as a mouse, tears were streaming from her cheeks as she was really listening to my words. In that moment, I stopped my closing and walked over to Sandy. I got down on my knees next to her, put my arm around her, and just held her close. About a minute, maybe two passed without a word spoken. Sandy finally said, ‘I’m OK, I’m OK,' and smiled and nodded at me. I stood up and resumed Closing Argument. I never commented to the jury on that moment. They felt it. I felt it. I believe TLC helped me develop the ability to be in that moment. That was the really special part of the trial."

Want access to the interview transcript? Click here for a downloadable pdf.