A thousand-pound gate falls on a woman. The last thing she remembers is being on the property and going down stairs. She suffers a TBI. The defense's theory: She’s a liar. So is her husband. So are the fire personnel who responded. And the bystanders. Sagi Shaked takes host Dan Ambrose through the play-by-play of how he exposed the defense’s “conspiracy theory.” The jury saw through it and awarded a $4.5 million verdict. He also breaks down a case where a client stuffed a component TBI after his vehicle was T-boned. Sagi turned a $200,000 offer into an $800,000 verdict. And Sagi previews his TBI masterclass at TLU Beach, where he will explain why plaintiffs’ lawyers may be undersettling their cases – and how to avoid it..

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Episode Snapshot

1. Sagi got involved in the Tampa auto case — a T-bone collision with a passenger client — just four months before trial, when the defense's best offer was $200,000.
2. The client had drugs in his system at the time of the crash; the defense argued that the evidence of the drug use should be allowed. Sagi successfully persuaded the judge to exclude it.
3. In the premises case, a 24-foot, thousand-pound gate fell on Sagi's client at an industrial complex. The defense offered $50,000 on the eve of trial and argued that she had simply fallen down the stairs.
4. Sagi used the fire rescue officer's report — written before any lawyer was involved — to get four bystanders' statements admitted as excited utterances, after the officer testified the scene was "frantic" and people were "in shock."
5. In his TBI masterclass at TLU Beach on Friday, June 5, Sagi will cover identifying TBIs, medically managing the case, deposition prep, and trial sequencing.

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Today we got my good friend Sagi Shaked here and we are at the new Hermosa Beach TLU Trial Dojo. And it was great because Sagi came in last night and we had a little happy hour, a few friends over.

We did.

But because we were thinking ahead, we got the dojo, we got extra rooms besides for me. So Seghi was able to ... How was your first night at the trial dojo Sagi?

It was awesome. We had a great time with a bunch of friends, get together and then we had drinks obviously, and then get to talk about cases and-

Down at the strand, it was only about a hundred yard walk, although it was a little windy last night because we had an unseasonable storm here. It costs for a little leak up there in the corner, but we're going to get that addressed. But it's a good thing it started early so we can address the problems of the dojo early, knock all the kinks out, get all the wiring done, and boom. Then we're going to be ready to really work on some of Sigi's big cases here. But the

Connections were there. We made connections and that's what it's all about.

Yes. And so Sigi, speaking of trials, you've had a couple trials recently, so that's what I want to talk to you about those. I want to talk to you about what you're going to be teaching at TLU Beach this year. And also a couple ... I know the thing you're most excited about though are you got your two children, your son who's going to start scredging from UCLA this year. Is that right?

Correct. Yeah.

And going to Georgetown next year?

Georgetown Law.

And your daughter is where?

At Georgetown Law.

Look at that. They got to stay. What a close family. Both. And they both went to school in California.

Correct. Yeah.

See, they got good tastes because California is quite superior to Florida. Much more free thinking out here. Little less, all that red mega correct, a little less. I mean, you're in Huntington Beach, you might get a little more ... I got people that don't want to come to Hunting Beach like it's too magna. I can't help what the people believe in the neighborhood. It's a nice hotel. It's our hotel. So if you don't want to come, I can't help it, but I think you should put aside. I personally, I mean, I understand where they're coming from, but that's going too far, not coming to Hunting Beach. But anyways, so I know that that's part of a lot of your motivation with your kids becoming lawyers.

Yeah, absolutely. I really can't wait for them to come in and practice and they're both excited about it. So it's going to be in fun.

So Sigi, you've had two trials in the last few months, so I want to discuss those with you. So the trial you had back in December, give us the backstory of that trial.

So it was an auto collision. Client's a passenger. It was issues with drugs. He sustained a jaw fracture, complained of neck and back, and then had a component of a TBI in it as well. Not in the trial, but those were the initial or complaints throughout.

And so to give a little context, what was the highest offer from the insurance company?

So when I got involved, the highest offer was $200,000.

Okay. How far before trial did you get involved?

About four months before the trial.

And so when you get involved in a case that you did not work up, what is your process to get that case ready for trial?

So as soon as I get the case, I want to make sure we meet all the deadlines because in Florida, the judges have really hampered down on or gotten strict on these deadlines. So make sure we meet all the deadlines with witnesses, get all our exhibits in order really in advance because you have to exchange very early on. You can't do it the week before. And then study the case. Is there something bad about the case that's going to hurt us when we get to trial? Or is there something that's going to hurt credibility? So I'm always looking at credibility in every case because without credibility, I mean, you lose your case. So that's kind of what I'm looking at.

Okay. And so you said the highest offer before you got involved was 200,000. And where was your demand at?

So we were at a million. We wanted the policy limits and they weren't budging. They weren't going to pay that. They said this is their best offer and they never really went off that. They wanted us off the million. We wouldn't come off the million. So this is a case that happened in Tampa, Florida.

TLU Huntington Beach is going to be the greatest event of 2026. There's going to be four lecture tracks, eight workshop tracks with the top trial lawyers in the country. On Tuesday, June 2nd, there's going to be a golf outing and also a pickleball outing. That night, we're going to have a dinner at the L'Oreal. We're going to buy it out so everybody gets a chance to meet each other beforehand. And then during the conference, of course, we do a full breakfast, full lunch, and theme parties every night. This year, we're going to be utilizing the pool area and the restaurant for more of the parties. And we're going to have an adult swim right one night, a Sach Oliver party on Friday night. And the last theme party's going to be a 80s run DMC Adida jumpsuit. It's going to be the greatest. And last year we had over 800 people.

This year it's going to be over a thousand. So if you want to be part of it all and you want to stay at the Paseo Hotel, don't delay because it sells out fast and then you're going to be in the overflow. Can't wait to see you there. TLU Beach.

Okay. And you say it was an auto case. So I mean, what was the context of the case?

So a

Collision? What was

It? It was a T-bone collision. The defendant made a left turn right in front of our client who was a passenger in the car. This was around 2:00 AM in the morning. And I'll tell you other things. Like I said, the client had some drugs in his system at the time.

What kind of drugs?

So cocaine, meth, and also a little alcohol. Never hurts.

You know what? It's a good combination. They call it the party cocktail, little cocaine, little meth. It doesn't little cocaine meth and alcohol in their system just from walking around. I mean, how do you function without a little pick me up here and there, combined with a little depressant to just mess with your system a little bit.

So we did file a motion in limine on that issue. And then when we were in the trial, the defense claimed we opened the door.

How did they claim you opened the door?

So the plaintiff was on the stand at that point. It was day two in the trial. The plaintiff was on the stand and it was through an interpreter. Even though he understood English, he still wanted the interpreter. And he said after the collision, he felt dizzy, he felt confused. And so defense got up and said that the door was opened because we all know that anyone who uses cocaine or meth is going to feel dizzy and confused. Now, I don't know that, right? Do you know that?

I think cocaine really helps you focus. Now alcohol meth, I can't comment, but I've seen people use cocaine before.That's the extent of my knowledge. And they seem pretty focused.

More focused, right? More

Focused. They got a lot of energy. They're just jumping. They got so much energy.

So the defense in the case, they were trying to tell the judge, "Judge, this evidence should come in because we all know, everybody knows that when you use cocaine, you get dazed and confused." And I'm like, "Judge, I don't know. " I think if they wanted to bring that evidence in, they should have gotten an expert to talk about the effects of cocaine on the brain and how it impacts the person's perception, reaction. Does it cause dizziness? Does it cause confusion? So the judge thought about it and gave us 20 minutes to come up with some research and then ultimately he excluded that. We didn't open the door, thankfully. Who wants to give money to a guy high on Coke and doing meth and alcohol?

You know what? That's a good point. That's a good point. So we got a little context of the case and now you're getting ready for trial. So in this case, when you get to the court, what is your focus in voir dire for this particular case?

Yeah. So because my client was a passenger in this case, in this collision case, I really didn't think that they were going to dispute liability. Initially they did, and then the morning of, they think they're going to trick us, right? We're going to admit liability. So we prepare. Before we get to voir dire, I'm always preparing two types of voir dire, two types of opening. One, if they take the route that they're disputing liability, and the other route, if they're not disputing liability. So in this case, right before we started voir dire, they admitted liability, which I thought the right thing to do. And so the focus of the trial changed. It wasn't, "Hey, I got to prove liability and damages or causation and damages. It's damages." So everything in voir dire was dealing with damages, money and damages. I wanted to make sure the jury in Tampa would be able to compensate us for that.

Because the jury in Tampa, just to give people context, is a little less generous than juries in perhaps Miami where you're from.That's

About accurate.

That's about accurate. And so the top concept of money, give us some ideas of the questions you asked the jury because I know we got a little pushback from at least some of the jurors.

So one of the questions I like to ask in every trial, and it's a fair question to ask. How many people, as you sit here today, have any trouble, even a little trouble, compensating someone for their injuries? And we had just a basic question, not even talking about millions or anything like that, just compensating someone for their injuries. And we had a young lady who was a teacher, elementary school teacher, and she raised her hand and she's like, "I can't do it. I'm not going to compensate anyone for injuries. I make 50, $60,000 a year. I don't remember the number she said. And I work hard for my money. Why should they get compensated for their injuries?" And then you start seeing other people agreeing they're nodding. And so you start following up with everybody on those questions because if they don't want to compensate, forget about millions or even asking for that kind of money.

If they can't compensate just for a person's injuries, that's a problem.

Yes. And so a lot of people, when they get those kind of answers, they get like, "Oh my God, this is such a bad answer." But we know from, as we get more experienced that that's actually a great answer and it's a great thing to have because now we can take that because like when I help teach people voir dire, I always tell people when they get an answer like that or any kind of resistance, you have to meet people where they're at before you can take them where you want them to go. So somebody says something like that, the best thing to say is, you know what? Something along the lines of, that's a great point you bring up and I bet you're not alone. I bet there's probably a lot of other people here that maybe feel a little bit like you do.

Who here feels maybe even just a little bit like juror X? And so now kind of encourages that kind of free brutal honesty and then you find other people that you need to identify quickly to get off the jury because when somebody believes like that, there's not a whole lot of "I obviously want to rehabilitate somebody that ... " They're beyond rehabilitation if they have that kind of mindset. And so that kind of basic one, did you get some ... When she raised her hand, how many other people did you get off for cause?

And I remember the ... So she said that we would start off with a strike against us. And that's like the key in Florida. Based on that statement that she wouldn't want to compensate somebody who was injured, we'd start off with a strike against us. And then you start asking, who else here feels like, let's call her Ms. Jones, Ms. Jones, raise your hand or how many of you feel like Ms. Jones? And then I told them, "It's okay to feel like Ms. Jones. My parents are completely opposite when it comes to injury cases. My father doesn't like them. He just doesn't believe you should get compensated like you, Ms. Jones. How many people are like Ms. Jones and my father? Raise your hand." And then they start raising their hands. And we had about four or five people that we got off and there was a group of about 30 plus people there.

So to remember 30 plus names, thankfully I have the chart because it's hard. So I was able to help get some people off there.

I bet. And so after we get through jury selection, let's talk about, obviously we've got openings, but let's talk about the sequencing of witnesses admitted liability as opposed to contested liability. So talk about how you think about your sequencing of witnesses and what you put up here.

So every case that I have starts off with damages. It starts with damages every day. It ends with damages every day. We're injury lawyers. So I usually like to see fire rescue as the first witness just to start the case because usually it's a witness that can't be impeached. They really don't have a stake in the game and they come in and deliver the testimony. What's the defense going to do? A guy's jaw was fractured at the scene. Yeah, he didn't complain. So in this specific case, when we started the trial, we had dropped the claims for the neck, the back, and the brain and only went on the jaw fracture for this specific trial. So

It was a jaw fracture case?

Right. Because the other issues, the neck, the back and the brain, they didn't come about till almost seven, eight months. The brain didn't come about till almost two years later. It's really hard to relate those injuries to the crash when you're talking about that much time goes by. And that was what the defense was going to harp on. Why did they wait so long? In fact, when we started the trial, before the openings, you saw them come in with these huge boards. I'm talking about boards the size of a huge monster TV, but like six of them where they were going to put them up all on easels. So imagine one, one, one, one, covering the entire courtroom to talk about how big the gaps in treatment were before you saw the first complaint. So when we dropped those other claims, it kind of diffused their entire case.

We cut their entire case.

Join us April 15th and 16th in Hermosa Beach, California at the TLU Beach House. We are doing a two-day witness prep and direct examination workshop. The witness prep would teach you not only how to get your clients to remember their stories, but to relive them, and then the direct examination so the jury just doesn't hear the story, but they experience it, they witness it. And this is right before Nick Riley's trial by human in West Hollywood, April 17th through 19th. So come for the witness prep, stay for trial by human. We'll see you there. So when they thought they were being tricky by admitting liability on the day of, they had no idea how tricky could be when you got three out of four claims and they got all this stuff to attack with. And now something that's almost unimpeachable because the guy broke some of his teeth, didn't he?

Exactly. He broke his jaw.

He broke his jaw. And so they had a tough time. I mean, they didn't just say it was a coincidence that his jaw broke on this day.

No,

No. They didn't go with that defense. But the crash, his jaw would've broke anyways because he had a preexisting weak jaw. No, no. Next time he ate anything that was crunchy, like cereal, his jaw was ... They didn't tell you, "Oh, I'm surprised." So they have something like that.

They didn't go with that. And what happened was really, when we cut out those other claims, we cut out their experts. You cut out their radiologist, you cut out their orthopedic, you cut out everything, and what do they do? The case falls apart. And they were called dumbfounded, I guess you can use. When we did that, he didn't know what to do. No one's ever done that to him last minute. So it was a unique surprise for him. Not for me, but- I'm used to

Surprising people. I'd like to make trial more fun and interesting and lots of surprises, not just predictable. Well,

The defense always does it. They'll admit liability and say they're good people. We're doing the right thing here.

I don't suggest you shouldn't surprise them. I mean, that's part of the strategy of trial, right?

Absolutely. That's what

Makes it fun and entertaining. Every day's different. Every day is a different strategy. And there's

Always something crazy that goes on in a trial. Like I told you when we opened the door or they claimed we opened the door, there's always something. And in fact, in this case, I'll tell you about the jury. Remember the story we talked about? Yeah.

So we're about to close on this case and it's four o'clock on a Tuesday and the judge asks the jury, "Do you want them to close now and stay through as late as you need to to get this case done or do you want to come back the next morning?" So jury, they take a vote and they want to come back the next morning. Of course, I wanted to close on Tuesday because if we closed on Tuesday, I was ready and this defense lawyer was still trying to catch up with what happened on Monday. So judge lets the jury go down. So jury goes downstairs, my client heads downstairs, the defendant heads downstairs and we're packing. We're getting our stuff ready to go back to the hotel room to continue to prepare for closing. While we're packing, I get a text message and my co-counsel, Brian, also gets a text message and it's a picture.

And I really don't know what this picture is. I'm like, "I see two people. " And then it's a video and I'm looking at it. I still don't understand it. So I call the client, he's like, "Do you see what I just sent you? " I go, "Yeah, but what is it? " He goes, "The defendant is walking with one of the jurors." I'm like, "Oh, this is interesting because we all know you're not supposed to talk to the jury, right? That's common sense." And so they're walking for about three blocks into the parking lot. So I really don't know what to do. So next morning we bring it up in front of the judge. We're like, "Judge, we have an issue here." Our juror was talking to one of the defendants. And so the judge brings in each juror individually and asks them questions.

Finally, he gets to the juror that was talking to the defendant and the juror admits, yes, we were talking. We were only talking about the weather in Tampa, how it was really cold, and this was in December, and that there was a homeless problem in Tampa, in the downtown area. So being that, the judge didn't think anything of it, I was kind of concerned that they developed some sort of bond. Maybe they weren't telling us everything that was talked about. So we moved to get her taken off the jury and have the alternate replace her. The judge asked defense counsel if he has any objection. And defense counsel said, "I really can't object because they spoke." So that juror is removed and the alternate takes her place. And then the judge told us this, "Because closings are coming up, I don't want the jury to think anything.

We're going to let that juror sit, listen to closings, but she doesn't get to go back into the jury deliberation room." Fast forward, we do closing arguments and the jury gets the case. They're now deliberating. So what happens? The judge tells that alternate juror now, the one that was supposed to be on the jury, "You can go home." And she's like, she raises her hand. "Judge, can I stay? "He goes," You can do whatever you want. "She wanted to stay to see what the verdict was. So, okay. So now I'm like, we can talk to her. So we go and talk to her because in Florida, if they don't want to talk to you, they don't have to, but she said she wanted to talk to us. So we start talking to her and then she tells us, "I liked your case." I'm like, "Okay, and I would've given you $3 million." Not a dollar more than three

Million.

You asked four to

Six.

Right. Yeah. Not a dollar more than $3 million. I'm like, "I don't know. I think I got rid of my best juror." So fast forward now, the jury comes back with their verdict and it's $800,000. So in hindsight, maybe, knowing what I know now from that specific case, I wish I didn't take her off, but I think every time I replay that situation in my mind, because you can always replay it and replay it and think, I wish I would've kept her, but I think I did the right thing there.

Come on, you can't leave that juror on there because you just don't know. It's too big a variable. And I mean, unless that alternate is horrible for you, it seems like a no-brainer.

Yeah, yeah. I thought she was good, but I was concerned about maybe they developed some sort of bond in the three blocks that they walked. So it was a little concerning.

So you 4x the offer, so that's a pretty good result.

Yeah.

But then the next trial you got, you did a little better than 4x because- We

Did a little bit.

A little bit better than 4X. And what was this case about?

So this trial is a premises case where a gate, it's a 24 foot wide, sorry, length, 24 foot length, eight feet high gate, weighs about a thousand pounds, falls on our client. And so we sued the landowner and sued the tenant. We resolved it with the tenant and now the case was just against the landowner. And so she had a TBI. The landowner didn't want to offer any money until the start of trial. They offered us 50,000. On

The start of trial?

Yeah. About a day before the trial, they'll say we'll pay 50,000.

Was he insured?

Huh?

Was he insured?

He has property. So the insurance ... Yeah, there was insurance, but not for that amount what we wanted. So he has property worth over $5 million. All

Right.

So it's a problem for him. So we start the trial, they only offer 50 and my client-

What was your demand?

350. Because we had settled out with the other entities, so we were ready to get this case resolved and we just couldn't get there. So

They wouldn't get up to 350.

They would not.

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So the defense took the position that when that gate fell on her, there was no eyewitnesses other than her husband, and you can't believe her husband because he has an interest in the case. The defense claimed that she fell in the property, not that a gate fell on her. And one of the challenges that we had was there was four witnesses, according to fire rescue. When the fire rescue got there, the gate had been lifted already and put back in its place. So the defense said, "How could a thousand pound gate be lifted and put exactly back in its place?" That was one of their issues. Fair

Question.

Another issue is the four witnesses, nobody knew who they were. And this was a industrial kind of a complex and the defendant himself said, "I went to everybody. I know I worked there for the last 30 years. I know every single owner there. I went to everybody and asked if anybody saw this happen and nobody saw it happen." The defense claimed the gate had been put in 17 years ago and never fallen. Nobody ever had an issue with it. So when we tried to get in the statement of fire rescue, because in his report, the fire rescue said four people told him that a gate had fallen on someone. And so we had him come and testify, and then the defense wanted to voir dire him on the issue of- Present sense

Impression,

Excited

Utterance. Is there some- Exactly. Is there an exception to the hearsay rule that would allow these statements to come in?

So what the fire rescue testified to was, I've been doing this for many years and tell me an auto accident, I probably wouldn't remember, but when there's a gate that falls on someone and the issues surrounding that happened then, that's an incident I do remember. Okay. So what do you remember? He said it was frantic. People were in shock and they were telling me that the gate fell on her. So what do you think I'm thinking when I hear frantic and shock?

Excited utterance.

Excited utterance. It comes right in.

Evidence. We know it.

Yeah. So it's like one of those exceptions, right? And I'm like, "Ooh, frantic in shock." And clearly the fire rescue, you can tell he was a little upset with the way the defense lawyer was questioning him. The defense lawyer was trying to say, "Hey, as if you're not telling us the truth." It's in his report. Before any lawyer got involved, before anyone got the case, he said in his report, four strangers or four bystanders, he called them, told them the gate fell on her. And so we got that statement in and that was important for the case, obviously, because then it's just the husband saying it.

Now it's not just the husband

Saying it before the

People verify, even though who these people are.

Right. So that was one hurdle in the case. Another hurdle in the case is the client hadn't gone to treatment for a very long time and that's always- What's a very

Longtime? A year,

Two years? A year. And that's a problem. And then there was gaps between that treatment. So anytime you don't have someone going or managing the case, going to treatment, it's a problem because the defense is going to harp on that. And they did, obviously.

Can't blame them. They're trying not to pay money. You're trying to take their money. You got this tension

With

This money tension, all right? And

Then another issue is the last thing the client remembers, because she claims she passed out, but the last thing the client remembers is being in the property and going down some stairs, and that's the last thing she remembers. So the defense, they make the whole case about, this is not a gate that fell on this woman. Remember what she told you. She fell. She remembers going down the steps and nothing else. And that's kind of how they argued it in closing.

That she fell down the stairs and the

Rest of the system. She fell down the stairs because that's the last thing she remembers. And so they pulled up a picture from the gate and you see these stairs over here, that's where she fell. And I kind of prepared for that because I thought it was the most outrageous argument to make. Why would someone ... Because he's calling her basically a liar. He's calling the husband a liar. He's calling fire rescue, a liar. And the four bystanders, they're liars too. It's

That big

Conspiracy. And then the person that called 911, that person's also a liar. So everyone- Who called

911? Something

Stranger. We don't know who it is.

Did they say a gated fell?

Yeah.

Okay.

But that statement didn't come in, but-

Why did not come in as an excited utterance for present such

Impression? We don't know who it was and we don't know what they said. The judge wouldn't allow it in.

We know we don't. There's nothing that says you have to identify an excited utterance. Where's that in the rules?

We couldn't get it in, but we got the fact that someone called 911 and it wasn't the husband. Got it.

And so when I got back up, after they did their closing, I got back up in rebuttal and I'm like, "Did I just hear right?" He's saying that this thousand pound gate didn't fall on her. That didn't cause her to fracture her nose or the orbital fracture. That's not what caused it. And then you see me running in the courtroom. This is where she fell, where the stairs are. And then the husband, he picks her up and he runs over to the gate, puts her right near the gate. Somehow the husband manages to take this thousand pound gate, put it down on his wife. Nobody else sees it, right? And then he manages to get four bystander in cahoots with the person who called 911. And then he also manages to get fire rescue to do the same. Now at the same time, I'm looking at the jury and some of them have these big smirks on them.

I don't know if they're smiling at me because it makes sense what I'm saying, or they're smiling at me because I'm being ridiculous with my argument. Obviously later we found out that they were on my side. So what I argued was everyone's in on this conspiracy, fire rescue, the bystanders, the person who called 911, the husband, everybody's in on it, except the person wanted to take responsibility. And obviously the jury came back in her favor.

Yes. Well, let's back up a little bit because this was a contested liability.

Correct.

So the last case we talked about was admitted liability. So how is your approach to voir dire I assume is a little bit different ... It now.

Yeah, absolutely. I want to hit the issue. So in this case specifically, one of the issues was that gate was not built up to code. So there's something called the South Florida Building Code and you have to comply with the code. And if you don't build it up to the code, it's a violation. And it can cause people, dangerous things can happen. And the code is what you call the minimum standards. So one of the things I wanted to get out in voir dire that the law is on our side. How many people think that you should follow the law? Following the law is very important, right? So I want everyone to agree that the law is important, following the law is important, and they're all going to do that. Whether it's the jury instructions, whether it's the plaintiff or defendant. Nobody is above the law.

Can we all agree with that? And they all agreed with that. So that was one thing that I wanted to know. And then this was an incident where we're claiming a gate fell on someone and they got hurt. So anybody have a problem with people who get hurt and bring claims. Some people had a problem. I think in every panel across the country, there's always going to be someone who says can't compensate for that. But my thing was, this is the law. If you follow the law, then we're going to win. So that's kind of what I wanted to get on liability there.

Okay. And then as far as the sequencing of ... And I assume you do all the same, similar type of damages, voir dire, obviously.

Sure.

And then how about the sequencing of witnesses now to contested liability?

So case is always about damages, whether it's contested or not. But going back to voir dire, in this case, I thought it was a case that we can get millions of dollars on. And so I wanted to ask the jury about cases that juries have awarded millions of dollars on. So how many people here have heard about other cases in Florida where juries have awarded millions, tens of millions of dollars? Raise your hand. How many people have any problems with juries awarded tens of millions of dollars? So we did that a little different than the Tampa case. And then going to the sequencing, again, I'm a personal injury lawyer. It's about damages. Every case is damages. So again, how did this case start? Probably like most of my cases. Fire rescue coming. Talk about what they saw.

Talk about the four excited utterance bystanders.

Absolutely. But also talk about the damages. It's the damages case. So that's really what you want to do. For me, again, it works for me. I'm sure everybody has their own way of doing things, but I like damages.

I like damages because it's about money.

Yeah.

And you like money too.

Absolutely.

Absolutely. And so this case, their maximum offer is 50,000. What was your ask of the jury? What'd you tell the jury it was?

Six million.

Six million. And at the end of the day, what did the jury tell you it was worth?

4.5 million.

Okay. So they were a lot closer to you. So if you do that 50 times 20, 20 times four and a half. So basically you did 90x your offer. That's a little more. The last case we talked about, the 4X your offer, I'm like-

This was a little better. A

Little disappointing. I'm like, I don't know if you deserve a stage at TLU if you can only 4X an offer, but-

It's true.

Now that you can 90X an offer,

Now I want the red carpet. Now I want the red

Carpet. I don't know about that, but at least you have the chops. I'm going to make sure you got the chops before you come to TLU because I think at TLU Beach, have you been to every year the last four years?

I have. All

Right. So you've seen ...

The evolution. The evolution. How it's grown and it gets better. It really is the best conference out there. If someone wants to learn and connect with some of the best trial lawyers in the country and just share ideas and share thoughts and become friends with people who we talk about the same things. Sometimes people get tired about me talking about cases if they're not in that world. And they're like, "Oh, that's all you'll talk about. " I'm like, "That's who I am." So it's kind of hard to not talk about that.

People are like, "Are you always on? " I'm like, "You're always on. " I'm like, "What does that mean?" Yeah, because all my friends are lawyers or generally in the industry. Somebody that is an engineer for a living. I'm sorry. I'm not going to have enough in common with them to even have a conversation to give a rat's ass. I'm sorry. I don't mean to be so superficial, but if you're not in the law of business ...

Well, you see it. Someone who's in the law and you start talking about your case, their eyes lied off. In your eyes, I'm like, "Wow, they're interested too." I'm like, "Okay. Now we talk." Now you're having conversations and you're getting ideas and it just gets better and better and better. So that's what TLU does. It gives people, again, that chance to really connect with like- minded people who really want to help others, people who've been victims for no reason at all. And so it's a great way to help your clients by coming to Huntington. I always learn when I go, whether I'm teaching or I'm always learning from others too.

Sagi is the, without a doubt, the world's greatest students. As long as I've known Sigi, which has been, I think we first connected in Baltimore probably 11 or 12 years ago, I don't really remember through Connell, but every day, every day of the AAJ, and we're on our way down this afternoon, every day you'll see Sigi there with his suit ons and with his laptop out in class, the rest of us are out hanging out, having coffee, seeing the scenes, not Sigi were Sid. He's in class. I've always been impressed with that, especially some of the very mediocre presentations that you sat through because I know your mindset is like, "I get my work done while I'm here, do some emails." If I hear something that ... They're likely to have one nugget there and that our presentation, they're going to have one thing that you say, "Okay, I can apply that to one of my cases." So the consummate student of the game, which is helpful though, because you got to stay curious in this game.

Sure. I mean, if you're not getting better, you're getting what? Worse, right? So I'm always trying to get better, trying to improve, trying to learn from other people.

Join me and my mentor, David Clark, May 27th through June 2nd in Huntington Beach, California for a dark arts bootcamp. This program will change your life. Dave will teach you about neural linguistic programming, conversational hypnosis, embedding stories in the unconscious mind. He changed my life and he'll change yours. And I'll coach you on your witness prep and direct, cross-examination, performance skills for opening statement and closing argument and voir dire. These days will change your life. Come for the bootcamp, stay for TLU Beach, the greatest conference ever. And I know because you told me, but like in this last trial, because some of this to training we've done on connection and even though you've only done a little bit, you haven't done the full bootcamp yet, but even the time that we spent a little bit, how did you apply some of the skills that you learned in this last trial?

So what you taught me is completely different than what they teach you in law school. Go back to law school and they tell you when you're doing your presentation so you don't get nervous, don't look people in the eye, look between the two people. And I'm like, "That's a horrible way." Knowing what I know now, right? I've been doing this now, this is 2026, so 26 years, what a mistake that was, right? Because you have professors who, nothing against professors, right? But they're really not trial lawyers unless they're teaching trial advocacy and this is

... Even then, they're like judges or prosecutors, people that never really had a fucking ... The difficulty of trying the case is like a plaintiff's lawyer or a criminal offense lawyer. Those are tough cases. Being a prosecutor is a joke. Being a judge, all due respect is a very easy job. You get to sit there and do whatever the hell you want and everybody laughs at your jokes even if they're not funny. And it's a government steady paycheck type of job. You just don't find the most brilliant, ambitious people wanting to be sit on ... Could you imagine going from where you're at to being a judge? Forget about the fuck. I think a

Judge is a very important job. I don't want to be a judge,

But it's a very important job. I mean, feel like somebody like the way we're wired though, forget about the money. The thing that the money was the same, but to sit there every day and just call balls and strikes instead of being the guy at the plate where the bass is loaded, it would be horrible,

Horrible. But going back to your connection, so what I learned in law school was completely wrong. The way you connect with someone and how you're teaching it and to connect with making that eye contact, and not just eye contact, but really connecting with that eye contact with that juror or the next juror or the next juror and keep going. It makes a difference. And I think it made a difference, and especially in the last case where they can feel that I'm on their side, we're together. This is us against them, right? We're going against the defense. They're the big, bad bullies and we're here representing the righteous person, the injured person. So we do make a connection and teaching that connection, I know it's easy, it sounds easy. Oh, just look the person in the eye. It's not easy by any means. It's practice and repetition.

It's really difficult.

Practice and repetition. All right. Speaking of practice and repetition, this year you'll be teaching your TBI masterclass and you taught it last year. And so I know you've made some changes this year. So that's a one day class you're going to teach on Friday, June 5th, all day long. And so what will people who decide to sign up for your class, what will they be getting from you?

So if you haven't tried a TBI case or you're looking to try a TBI case-

Or you're looking to get better at trying TBI

Cases. Or even just identifying them and working them up because I guarantee you everybody has them, but they're probably undersettling them. So what I'm going to do during the class is first, how do I identify a TBI because it's not just an orthopedic case, there's also a TBI component to it. So one, identifying it. Two- So

Speaking of identifying though, what are some of the big myths or things that people think they need to have to identify and maybe overlook?

So the number one myth, and we heard it in this last trial, is you have to lose consciousness. It's not true. And so that's like the biggest myth. You'll hear every adjuster tell you they didn't lose consciousness. They can't be brain injured. That's not true. The literature is out there. You don't have to lose consciousness. If a person's dizzy or confused at the scene, that's a sign of a brain injury. So don't just let the insurance company, whether it's the attorney, what they teach at the Defense Research Institute or the adjuster, don't let them persuade you that your client doesn't have an injury. And usually on these TBIs, I'm talking about the mild traumatic brain injuries, not where someone's head has been cracked open or you have fractures in the head. I'm talking about no fractures, you're trying this case or you have this case, you're going to get a low ball offer.

So you've got to get prepared to work the case right from medical standpoint. And then you got to get prepared to prepare your client for your deposition, prepare them for that DME or CME, whatever you want to call it, and then for trial. Otherwise you're going to get low offers, you're not going to get the full value of those cases.

Right. So first you said, so part of your class first identifying it and then beyond identifying it, give us the other steps that you're going to walk people

Through. Identifying it, understanding the medicine, so now you can medically manage the case, right? Identifying what doctors can help your client medically, because you don't want to just send ... It's not just a case. You got to also help the client get the right treatment, right? Are these doctors able to help your client get better? It's not just about a case, right? Yes, we want to get the money and the money's great, but you want your clients to get better because we're not just in it for the money. And then once you've done that, now you're going to have depositions. A lot of times clients can't remember what happened. Don't make them remember what happened. If they don't remember, that's a fact. They lost consciousness or they didn't, but they may not remember. They have amnesia of how the crash occurred. That's fine. So preparing for that deposition, preparing for that CME, and then getting them ready for trial and what exhibits you need to use, how you talk to the doctors, maybe a direct for a doctor.

And we're going to do some sequencing for some jury selection questions. And

So when you get ... I know a lot of the cases that you work on, a lot of cases you try are brought to you by other lawyers, typically, like you said, a few months, four months, five months before a trial. So of course people get their case, try to work it up, settle it so they can keep the money for themselves. They don't have to bring in- Of course. I mean, that's natural. People want to make the most money they can for themselves to get it. But when it gets to that point, so what are some of the mistakes that you've seen with people in their medical management before they bring you the case?

So we'll talk about one, gaps in treatment. The defense loves gaps in treatment. If your client is hurt and you're going to trial on an injury case, the jury wants to see people that are still going to treatment, because if they're not going to treatment, they're back to normal. So that's one mistake that I see in cases- That people

Are not properly medically managing their clients.

That's

Really what it is.

Yeah. I think that's a huge problem. And there's many others. If you come to the class, we're going to talk about them and how to address them.

And you said getting your client ready for deposition. So again, what are some of the big mistakes you see or-

So again, one of the mistakes, first of all, in a traumatic brain injury case, a lot of times, especially if they have a frontal lobe injury where it's impacting their emotional state, very difficult to prepare with a TBI victim for a deposition. So I see a lot of lawyers preparing the day before or sometimes the morning of the deposition. What a horrible mistake. Don't do that. If you have a TBI case, you need to put in five sessions. I know it's work and I would start about a month to a month and a half before, start working with them and you're going to get frustrated because they make mistakes. They don't remember much. So you have to drill with them, do the deposition and then have someone play the defendant asking them questions. And we're going to go through that, what I like to do during the deposition.

So that's another area we're going to address.

Yep. And for people that want more help on their witness prepping, March 6th and 7th, we're doing a witness prep and direct workshop right here at the dojo. Still got two spots available. It's limited to 10 people because we got to get lots of individualized attention on it. In addition to doing this lecture or this masterclass, you're going to do two hours of lecture on Thursday. Yes. And so what are we covering on those?

So on Thursday, we're going to address the major mistakes or defenses that the defense brings in auto accident cases, right? Hey, door accident, but people are using it. So auto crash, auto collision, the major defenses that we see and how to diffuse them. So we're going to identify them and then talk about them, how to diffuse each specific one. So if you start at the beginning and you address these and you educate your client because it's all about education, then you won't have these defenses. And some of them are self-inflicted. We talked about earlier gaps, right? Gaps in treatment can be cured if you educate the client at the beginning of the case.

Right. The necessity of continuing to go on. And so you're giving you two hours on ... Because there's a lot of mistakes people make that are costing themselves a lot of money.

Right. I mean, you're costing your clients a lot of money, and in return, you're costing yourself. So if you address these and you can put in systems in place so that it doesn't happen. Now, I don't know if you can address it if you're handling thousands of cases, but if you're handling a fair number of cases, you can address this and you give the clients that one-on-one time, you can really address this and change the value of the case.

Besides going to the conferences like the AJ we're going to today or TLU, I know you're a big continuing learner because I keep the stats on who watches TLU on demand. And always every month you're always right near the top of the list. So tell us how you've utilized TLU on demand to, I guess, help get to where you're at. How do you utilize it to improve your skills? So

One, I wish TLU on demand was available when I was a young lawyer. It wasn't. You'd have to go to conferences. So now having that on demand, and for me, I go running or I'll exercise. While I'm doing that, I'm listening to whether it's a podcast that you had or someone else's lecture, because I'm always able to get something out of it. So I'm trying to always get better, right? And if you're listening to that, you're getting better and then taking notes and then implement it into your case. So even if you listen 10 minutes a day, that's 10 minutes more of knowledge that you're getting from some of the best lawyers in the country who are sharing their information. I'm going and I'm sharing information. I don't have to do it, but I want to because I think insurance companies, they have their lawyers and they have their schemes on how to screw people over, right?

So here we're all coming together, this program that you put sharing so we can be the equalizer to what they're doing. So we want to help the young lawyers so they can get better and their clients can get real justice.

We're starting off the summer right, May 8th and 9th in Hermosa Beach, California at the TLU Beach House. We're doing a two-day witness prep and direct examination workshop. You will learn how to prepare your clients so they just don't remember their stories, but they relive them. And then we transition that to direct examination so the jury just doesn't hear the story, but they relive them, they experience them, they witness them. We'll see you there. Yeah. And so at TLU Beach this year, we're going to have five lecture tracks instead of four. So I'm kind of excited about that because the fifth lecture track is really a case analysis track. So all the people that have been busting their asses in the last year and going out and getting verdicts, but that are lesser known, right? Because there's a lot of great lawyers out there, but we just never heard of them or they just got their first seven figure, eight figure verdict.

And I think those are very significant moments in people's lives. I mean, I'm sure even you remember your first seven figure verdict, you remember your first eight figure verdict. You probably remember your first six figure verdict, right?

Of course.

Because it's a process. And so I'm really excited about this case analysis track I have because all the presenters on it are all people that have been coming to TLU and using the TLU on demand and working hard and working their cases up. And now they got some results and mostly, but just the way the world is, they wouldn't have a chance to present on them because there's only so many, almost so much room on every stage. And so I'm giving 18 people a chance that are going to be speaking on the trials they got. And I think it's really inspirational for people too, because they see somebody just like that. Not that Brian Panches, Nick Riley, Sagishak heads, not the people that have fucking been killing it for a long time that this is what ... Okay, because people always think, oh, I don't get cases like that or whatever.

That's not my life. Or that's not where I live. And just having seen this vast group of people from around the country getting from Atlanta to Virginia to New Mexico, getting great results. So I'm excited about that track. And then we have the four lecture tracks and seven other ... And so all those tracks are being recorded, like you said, for the TLU on demand, because you can't be in two places at once and-

That's the beauty of the on demand. So I go to what I want to watch and then sometimes you have amazing stuff going on at the same time. I can't get to everything, but the on demand allows me the ability to do that. If you don't have on demand, I mean, you shouldn't be practicing, really. It's just a key to getting better if you want to get better. If you don't want to get better, TLU's not for you. If you don't get better. If you're looking to get better, and not only if you step up your game, your income level's going to go up, obviously, because you're going to do better on your cases, but it's better for your clients. You're going to get them real justice.

And it's more fun to be a winner than a loser.

Absolutely.

And so, but this year we've got to have, like I said, five lecture tracks. They're all being recorded. Seven workshop tracks, which are the smaller group training, the interactive training, like your masterclass or Ben Rabinowitz and Mike Kelly have a cross examination of experts masterclass they do on every Wednesday of TLU. They've done it. Started out in New York, Vegas, even though we're not doing Vegas anymore, but Huntington Beach. And so there's specialized learning on smaller groups. I'm doing ... My people, my coaches are teaching cross-examination, performance skills, voir dire and Joe Fried and Joe Cameron Lengo are teaching a trucking class on Saturday. That's like a masterclass on beating Amazon and FedEx and like these massive logistic companies that they've been really teaming up and figuring out how to hold these people accountable. Because Amazon and like Uber, they don't want to be accountable for shit because that way it cuts into their profits.

If they have to be accountability for their drivers, for God's sakes, to try and set up that they're all independent contractors, we all know what horse shit that is because this year Uber's really trying to screw us in California with this initiative to give 75% of every settlement or verdict to the quote unquote victim/plaintiff and 25% to go to the doctors, the case expenses, and the lawyers. I mean, that would just put ... It put so many people out of business and if they're able to do it there, they'd be able to-

They know what they're doing. They want to cut out all the lawyers and make it seem that, oh, this is good for people, but nobody's going to take your case. Yeah,

You're not going to have a lawyer and you're not going to get shit. So that is a big important thing we're doing this year to do this because just like last week, I think I moved into this house on Monday, but on Sunday, for the week before that, we were out at Nick Raleigh's place in Big Sky doing a bootcamp out there, like a ski bootcamp, which is one of my favorite things to do is skiing and a bootcamp. But he has this big ass house out there. It was like 12, I don't know, it was huge and it's really nice. I mean, like this area right here, like his common area is probably six times the size maybe of this common area where

It's just

Like these massive ceilings and beams and the view is the mountains and the snow and the background. And I mean, it's an impressive place, but he gave it to us to use for the week so that we could do our bootcamp and a fundraiser. Because actually the whole ski camp started five years ago because he was back then, he was fighting the cause to ... He's always got some cause he's fighting. He's a very philanthropic trial lawyer. And that was to reform the MedMouth laws back then. So we did one. We were supposed to do his house out there, but if something came up, we couldn't. We had to go to Tahoe. So we'd be going to Tahoe for a fewears. Good thing we didn't go this year though because there was an avalanche and six people got killed like about just a few days ago.

I mean, I wouldn't have been out back country skiing. So unlikely I would have been in Avalanche territory, but still. So you

Raised money this time?

Yes.

And that was for the Uber initiative? How much did you raise?

54,000. That

Was TLU?

Well, it was- In

Combination.

I was the organizer

So that people came and paid tuition to that amount. And so that way they either paid it directly to the Uber or paid the tuition to me that I'm going to forward to the Uber initiative. So I was really pretty thrilled with that because a lot of these people from out of state too, which they'd never be giving money to most likely. I mean, you're not just donating to ... Out of state lawyers, usually you focus on your own initiative, but you're not too often. You're like, okay, I got to go give $10,000 to these people in California because I'm very concerned about the Uber in California. So not as likely, but it was a great time. It was good cause and that's important. And a lot of the ... We're working on having more of these bootcamps this year to raise more money. Dee Robertis just called me yesterday.

He says, Hey, if I do a bootcamp in March, can we do a bootcamp for Uber if my trial gets moved? Because D Robertus is like the employment king and when he does a bootcamp, all of these employment people sign up, so that's going to be pretty great. And I think that's about everything we had to cover. But there's one thing that's very important here that we forgot to mention is that this episode of Trial Lwyers University is being brought to us and sponsored by, is it Preferred Capital Funding?

Yes.

Your friend Brian Gorelli

Is.

Because we had a little happy hour last night that he was co-sponsoring with the Chaket Law Firm and I invited Panish. I said, "Pash, you want to come over?" But he wasn't feeling so well, but he goes, he's like, "Really?" He's like, "That guy's the best in the business." I go, "Brian?"

Brian is the best.

Brian? Yeah. I'm like, "All right." I said, that was totally spontaneous. If you know Panish at all, one thing that Panish does is not, he does not sugarcoat shit. If he doesn't like somebody- Straight to the point. If he thinks somebody's full of shit, he'd be like, "Ah." And he's rarely infusively complimentary of people or other businesses, but I thought that was pretty cool because I've known Gorelli for a while. I didn't know he was just such a ... I know apparently, according to Brian, he's the best. And he's a guy you use too, so that must, and I know you look out for your clients too. So anyways.

We got to let him know.

We got to let who know?

Brian.

Oh, you know Brian, he's very ... I think he knows though.

He knows.

He knows. Right, Brian? He knows. Anyways.

Yes. And I did donate 25,000 to that Uber initiative, even though I'm a lawyer at Illinois. It was important to me when I saw that come up. So you're right, Dan. That stuff is super important and we all need to step up and fight the fight on that. That's right. Thank you. And thank you for those kind words. All right.

Well, it was Panish. I was just relating what Mr. Panish said. I'm not in the position yet that I need money from, but hopefully, who knows? I might have a law practice one day. You never know.

There

You go. All right. Well, so we're done with here. We're on our way to San Diego to learn a little bit more at the AJ. So Seghi, if people want to get ahold of you, how do people find Seghi?

So if anybody wants to get ahold of me, look, I'm always willing to help. And I get people who've watched the on- demand or have been to some of the classes that I've taught. I give out my cell phone. I'll give it to you here. It's 305-790-5037. If anybody wants to call, again, I'm always sharing information, sharing what I got. I believe that's the way to do it and so we can all get better.

Yes. We all got to get better. And if anybody wants a comp access code to tell you on demand, my email's dan@triallawersuniversity.com or myself wants 248-808-3130. And as far as the live conference goes, we give scholarships to law students. So if anybody you know is a law student, they want to come, all they got to do is send in an application and there's a strong likelihood. Very strong likelihood that'll be approved, like extremely strong likelihood. And if you're a lawyer and you really truly can't afford to come to TLU, give me a call and I will help you with the tuition because there's no excuse not to get better. So just keep that in mind.

Ready to train with the titans and set records with your verdicts? Register for our live conferences and bootcamps at triallawyersuniversity.com. Start getting your reps in before the big event by going to tluondemand.com to gain instant access to live lectures, case analysis, and skills training videos from the trial lawyer champions you love and respect, as well as pleadings, transcripts, PowerPoints, and notes for a roadmap to victory. Join the group that continues to get extraordinary results. Trial Lawyers University, produced and powered by LawPods.