SUCHOCKI & ASSOCIATES, P. C.
6320 SOUTHWEST BLVD SUITE 222
FORT WORTH, TEXAS 76109
(817) 338-0088
(817) 338-0086
Outline
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Introduction
Qualifications
 Board Certification in Personal Injury Trial Law
Experience
Litigation Management
Mini-Focus Group
Cost Management
Reporting
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Introduction
Twenty Four years experience handling civil litigation in
Northeast Texas:
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Trial experience in a wide range of civil litigation
Board certification in Personal Injury Trial Law
Appellate experience in civil litigation
Mini-Focus Group Risk Analysis
Cost Management
Comprehensive Reporting
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Experience
Tried Lawsuit involving:
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Nursing home negligence
Medical malpractice
Wrongful death
Service station gasoline fire
Residential fires
Oil field explosion
Tractor trailer accidents
Automobile accidents
Motorcycle accidents
Railroad crossing accident
Slip & falls
Trip & falls
Elevator malfunctions
False arrest, slander
Molestation
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Security violations
Trespass, conversion
Products liability
Hardware disease
Deceptive Trade Practices
Insurance bad faith
Uninsured/underinsured motorist
Business fraud
Breach of contract
Breach of lease
Breach of fiduciary duty
Construction accidents
Sexual assault
Dram-Shop
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Experience
In addition, experience handling cases involving:
 Defective Software
 Toxic Torts
 Life Insurance
 Health Insurance
 Real Estate
 Employee/Employer Liability
 Non-Subscriber Liability
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Experience
Appellate Cases:
In Re Donna Pack, et al., 996 S.W.2d 4 (Tex.App. – Fort Worth 1999)(orig. proceeding) [TDHS
records/investigators not subject to medical peer review privilege].
Davis & King v. Bryant, No. 2-98-283-CV (Tex.App. – Fort Worth 1999)(not designated for publication)
[Judgment affirmed – rear-end collision]
Hurley v. Markum, No. 2-97-299-CV (Tex.App.- Fort Worth 1998, pet. denied)(not designated for
publication) [Judgment reversed and rendered – premises liability]
Nassar v. Mutual of New York, et al., No. 01-96-01139-CV (Tex.App.- Houston [1st Dist.] 1998, pet.
denied) not designated for publication) [Judgment affirmed – personal injury on elevator
Chapman v. Ford, No. 05-96-00622-CV (Tex.App.- Dallas 1998)(not designated for publication) [JNOV
reversed and verdict reinstated – rear-end collision]
Allied Erectors Corporation v. Barbara’s Bakery, 954 S.W.2d 197 (Tex.App.- Waco 1997, no writ)
[Appeal of order denying special appearance timely perfected]
Butler, et al. v. Meridian Oil, No. 2-93-129-CV (Tex.App.- Fort Worth 1994)(not designated for
publication) [Summary judgment affirmed – wrongful death]
Deaver, et al v. Dairy Commodities, No. 2-91-191-CV (Tex.App.- Fort Worth 1993) (not designated for
publication) [Judgment affirmed – contaminated cattle fee
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Qualifications
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Board certification in personal injury trial law
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Over 100 actual trials
Engineering background with NASA See detailed resume
Special knowledge in accident reconstruction case
Special knowledge in software development
What is a Personal Injury Trial Law Certified Attorney?
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Counties where we have
tried cases
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Counties where we have
handled cases
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Litigation Management
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Litigation Management is a comprehensive management tool
and a courtesy that we offer to our clients:
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It provides management with total visibility
It categorizes cases in terms of degree of risk (liability and damages)
It conducts discovery & investigation consistent with risks
It recommends dispositions consistent with risks
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Litigation Management ensures attorney accountability and provides a
forum for discussion
 Litigation Management provides a vehicle for controlling costs
For more detail see Litigation Management
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Mini Focus Group
 Mini-Focus Group is a practical tool that we have made part of our
routine defense arsenal to assess risk and prepare for trial
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It utilizes candidate jurors to explore how they think and react to case
issues
It explores jury biases and common life experiences and how they affect
case issues
It allows the defense to construct a “trial story” that fits juror thought
patterns
For more detail, see Mini Focus Group
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Cost Management
We have a rational methodology for controlling costs that is an integral
part of litigation strategy.
 Background
 Records
elements
The
Discovery
ofare
facts
 Experts
 Production
 Interrogatories
Admissions Method
DateUnit
 Authorization
 Subpoena
 Online to Court Cases
 Internet
 PublicData
 Investigator
 Non-Stenographic Video
 Negotiate Rates
 Establish Budget
 Set criteria
for feedback
Control
 Interview
 Watchdog
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Cost Management
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A Data Unit represents a typical input of relevant information
A Method represents a way to obtain the Data Unit
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Cost management begins with an analytical choice of the Method
 Examples:
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Deposition v. Witness Interview
Video v. Oral Deposition
Subpoena v. Medical Authorization/Freedom of Information Act
Control represents the tasks utilized in maintaining cost efficiency by price
negotiations, discovery agreements, implementing budgets, imposing
spending limits, monitoring invoices and implementing advanced
technology
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Cost Management
Litigation Tasks
Background
Criminal
Legal
Pre-exiting injuries
 Records
Medical
Income Tax Returns
Personnel Information
Previous lawsuits
Discovery
Experts
of relevant facts
Method
 Production
 Interrogatories
 Admissions
 Authorization for Medical
 Authorization for Other
records
 Freedom of Information
 Subpoena
 Surveillance
 Online to Court Cases
 Internet
 PublicData
 Investigator
 Deposition
 Witness Interviews
 Video
Management
 Negotiate Prices
 Establish Budgets
 Letters of understanding
 Set limits for expenses
 Interview witnesses
 Examine each invoice
 Ask for price reductions
 Use digital photography
 Exchange discovery
in pdf format via CD
 Consider non-stenographic
deposition
 Discovery agreements
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Share records costs
Share deposition costs
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Cost Management
Method
Data Unit
Background
Criminal
Legal
Pre-existing injuries
 Records
Medical
Income Tax Returns
Personnel Information
Previous lawsuits
Discovery of relevant
Experts
Legal Research
facts
 Production
 Interrogatories
 Admissions
 Authorization for Medical
 Authorization for Other
records
 Freedom of Information
 Subpoena
 Surveillance
 Online to Court Cases
 Internet
 PublicData
 Investigator
 Deposition
Control
 Negotiate Prices
 Establish Budgets
 Letters of understanding
 Set limits for expenses
 Examine each invoice
 Ask for price reductions
 Use digital photography
 Exchange discovery
in pdf format via CD
 Consider non-stenographic
deposition
 Discovery agreements
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Share records costs
Share deposition costs
Oral
Non-Stenographic
 Witness Interviews
Telephone
In Person
Premise
Consider the most efficient and cost saving approach
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Reporting
Reporting is done according to client requirements
Reporting available over a wide spectrum
Summaries
• Sent by mail
• Sent by email
Client access to entire file
• Client can view any portion of file
• Client can download all of the file
Reporting is concise and direct and enhanced with visual aids,
including photographs, graphs, drawings and medical definitions to
facilitate communication
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Thank You