Designed and authored successful Motion in Limine to bifurcate trial on liability and damages as well as seeking to bar the plaintiff from the courtroom during the liability phase based on the prejudicial sympathetic nature of his appearance and inability to assist in his case. The plaintiff was a professional harness racer who fell during a race at a local track, suffering a severe traumatic brain injury which caused him to be a limited functional quadriplegic. The initial demand for settlement was $100,000,000. The plaintiff accepted a significantly reduced offer of settlement after the Motion in Limine to bifurcate and exclude the plaintiff from view of the jury was granted.
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