Tell your story through a

timeline(continue to left click for slide transitions)

Jane Doe meets her friend Linda Grey along with Grey’s Mother and Sister at Cantina Laredo for Dinner and Cocktails. Doe consumes red wine.

6:00PM

PRE INCIDENT FACTS SURROUNDING THE ACITIVITES OF JANE DOE

EVENING OFJUNE 26, 2009*

*Source: Linda Grey audio interview conducted by Officer Gellina on 07-10-09

Jane Doe meets her friend Linda Grey along with Grey’s Mother and Sister at Cantina Laredo for Dinner and Cocktails. Doe consumes red wine.

6:00PM

8:30Doe and Grey depart Cantina Laredo and head to New York Grill for dancing and cocktails. Grey’s Mother and Sister meet them there. Doe purchases a round of drinks

PRE INCIDENT FACTS SURROUNDING THE ACITIVITES OF JANE DOE

EVENING OFJUNE 26, 2009*

*Source: Linda Grey audio interview conducted by Officer Gellina on 07-10-09

Jane Doe meets her friend Linda Grey along with Grey’s Mother and Sister at Cantina Laredo for Dinner and Cocktails. Doe consumes red wine.

Doe and Grey depart New York Grill and head to Ouzo Blue Tavern for Ouzo shots while Grey’s mother and sistercall it a night

6:00PM

10:00

8:30Doe and Grey depart Cantina Laredo and head to New York Grill for dancing and cocktails. Grey’s Mother and Sister meet them there. Doe purchases a round of drinks

PRE INCIDENT FACTS SURROUNDING THE ACITIVITES OF JANE DOE

EVENING OFJUNE 26, 2009*

*Source: Linda Grey audio interview conducted by Officer Gellina on 07-10-09

Make your point by

emphasizing critical

distinctions in the law

440.02(3)(c)

“Employee” Includes:An independent

contractor working or performing services in

the construction industry

440.02(3)(c)

“Employee” Includes:An independent

contractor working or performing services in

the construction industry

440.02(3)(c)

440.02(3)(d)(1)

“Employee” Includes:An independent

contractor working or performing services in

the construction industry

“Employee” does not include: An independent

contractor who is not engaged in the

construction industry

440.02(3)(c)

440.02(3)(d)(1)

LIABILITY UNDER VERTICAL IMMUNITYACME

CONSTRUCTION

Plaintiff must prove by “clear and convincing” evidence that the employer deliberately intended to injure the employee;

or that the employer engaged in conduct that the employer knew based on prior similar accidents or explicit warnings identifying a known danger was virtually certain to result in injury and death, and;That the employee was unaware of the risk because the danger was not apparent and the employer deliberately concealed or misrepresented the danger so as to prevent the employee from exercising his informed judgment regarding performance of the work.

Emphasize positive findings

OSHA INVESTIGATION

OSHA INVESTIGATION

REFLECTIVE VESTS

OSHA INVESTIGATION

REFLECTIVE VESTSASSIGNED WORK ZONE TRAFFIC CONTROLLER

OSHA INVESTIGATION

REFLECTIVE VESTSASSIGNED WORK ZONE TRAFFIC CONTROLLERDAILY INSPECTIONS

OSHA INVESTIGATION

REFLECTIVE VESTSASSIGNED WORK ZONE TRAFFIC CONTROLLERDAILY INSPECTIONSADEQUATE WORK ZONE

Highlight important passages

Point out significant injuries

Torn rightRotator cuff

Torn rightRotator cuff

Bruised ribs

Torn rightRotator cuff

Bruised ribs

FracturedLeft

patella

Highlight important

deposition testimony

P. 7, L. 7-10

Q. Was there any discussion on the jobsite that standing water might cause a hazard to people that weredriving through it?

A. Yes.

Deliver your message

Clearly