330 Alhambra Circle

Coral Gables, FL 33134

633 S. Andrews Avenue Suite 400
Fort Lauderdale, FL 33301

(305) 446-5700

(954) 323-4400

Speak with an Attorney

Reaction to Las Vegas Hotel Suing Mass Shooting Victims

 

Earlier this week it was reported that the owner of the Mandalay Bay hotel in Las Vegas filed a lawsuit against more than 1,000 victims of a mass shooting that killed 58 people in 2017. The MGM Resorts International’s lawsuit does not seek money and appears to be a judicial bid to avoid liability and dismiss claims against it. On October 1st of last year, 64 year old.

Stephen Paddock opened fire at festival attendees before committing suicide. Paddock had set up a firing point with 23 weapons in the Mandalay Bay overlooking the Route 91 Harvest festival, also owned by MGM.

Trial lawyer Christopher Marlowe of The Haggard Law Firm, which has litigated hundreds of negligent security cases many of which were against hotels/motels,  says MGM Resorts International overwhelming failed to pick up the shooter’s behavior that day and had security issues that lead to the tragedy in the weeks and months before it occurred.

“MGM Resorts and Mandalay Bay, in addition to facilitating mass murder at the  Route 91 Harvest Festival in Las Vegas, are now attempting to use the court system to bastardize federal law and revictimize the families of those injured and killed on its property” says Marlowe.

He adds that the Federal SAFETY Act does not provide blanket immunity to landowners and operators who simply write a check to a security consulting firm which happens to be certified by the Department of Homeland Security.  The premise of this lawsuit against all of these victims is that, by hiring a certified firm, MGM had no further obligations whatsoever to its guests.

Marlowe says that the introduction to this absurd lawsuit states, “[Stephen] Paddock intended to inflict mass injury, death and destruction… The post-attack investigation revealed that Paddock brought in his van, which he parked in the hotel garage, 90 pounds of explosives, consisting of 20 two-pound containers of exploding targets, 10 one-pound containers of exploding targets and 2 twenty-pound bags of explosive precursors.”

click here to review notable Haggard Law Negligent Security Cases

The Haggard Law Firm partner adds “The “Seller” of the Qualified Anti–Terrorism Technology used at the festival, Contemporary Services Corporation, was presumably not in control over the security protocols and procedures relative to guests’ stockpiling of weapons at Mandalay Bay in the days leading up to this attack.  The shooter, in addition to the explosives he collected over a prolonged period of time, had twenty-three firearms in his hotel room at the time of the massacre. ”

The overwhelming failure by Mandalay Bay and MGM to appreciate the buildup of an entire militia’s worth of weaponry in a hotel room, by itself, is an independent and direct proximate cause of what ultimately transpired.  The hotel’s effort to immunize itself from negligence spanning not hours, but rather, days, weeks or months of security neglect, cannot be pawned off under a federal statute designed to protect purveyors of security technology for mass terrorism crimes that unfold in a matter of seconds. This particular act of terrorism required the kind of neglect that brings in boardroom level failures across every spectrum of hotel management – not just a few discreet minutes during a single music festival. – Christopher Marlowe

Continue reading “Reaction to Las Vegas Hotel Suing Mass Shooting Victims”

2018 Super Lawyers: All Haggard Law Attorneys Named to List

Once again, all Haggard Law Attorneys have been named to the latest edition of Super Lawyers. The 2018 list was released earlier this week.

Trial lawyers Andy Haggard, Michael Haggard , Douglas McCarron, Todd Michaels, Christopher Marlowe, Jason Brenner and Pedro Echarte are listed in the Personal Injury General: Plaintiff Category.

Our Appellate Attorney James Blecke was 1 of only 6 attorneys in Florida included on the Appellate List.

 

About Super Lawyers

Continue reading “2018 Super Lawyers: All Haggard Law Attorneys Named to List”

Slicing and Dicing Defense Experts – Negligent Security

 

 

By Michael Haggard, Managing Partner – The Haggard Law Firm 

Former Special Agents for the FBI, former CIA, decorated Soldiers, medical doctors with illustrative careers.  These are the individuals who make up the field of experts.  Their resumes can be impressive and most often, they present well to a jury.  Unfortunately for you, they are experienced, well composed, and generally speaking, very cunning.  Although it seems as though you are fighting a lost battle, it is accepting this realization that will help you the most in defeating the expert.

In terms of the negligent security expert, he/she will undoubtedly say it…“This crime was unforeseeable and unpreventable because the offender could not have been deterred.”  You could have a thousand armed robberies and twenty murders, but someone will sit across from you in a chair or on the stand and tell you it was unforeseeable and unpreventable.  As frustrating as that reality might seem, you should be grateful for having the knowledge of what the defense negligent security expert is going to say.  How you will use the statement against them is where your attack becomes most effective.

 

 

The best way to select your cutlery is by identifying which area of expertise the defense listed the expert.  The foreseeability expert will rely on certain evidence and the preventability expert will rely on different evidence.  At this point, you have amassed information from building your liability case and conducting research on your expert.  It is now time to select the appropriate materials to use against them.

The foreseeability expert traditionally relies upon the past criminal history of the property, the level of crime in and around the area, and the types of crimes occurring on the property.  As general as those topics appear to be, it boils down to what threshold the expert requires in order to determine if the crime against your client was foreseeable.  The threshold is something that will fluctuate depending on which side the expert testifies.  If he is testifying for the plaintiff, he will testify that it does not matter if a targeted crime occurred because a robbery is a robbery or a murder is a murder.  If the expert is testifying for the defense, then it makes all the difference whether the robbery was a drug deal gone bad or a targeted murder.  Knowing the expert will switch back and forth, you must determine if you are going to “gut” the expert right off the bat, or give them a thousand tiny “cuts.”

For example, we deposed a defense security expert in a case involving a convenience store.  It just so happens we had used this expert six months prior on a similar case involving a robbery at a gas station/convenience store.  After the introductory questions, I used the “gut” method.  I directly asked if he testified six months prior whether or not the defendant should have had an armed security guard.  He faltered and stuttered, trying to give an explanation on his contradictory opinions.  On our particular property we had at least seven robberies against the defendants customers, and at least four or five more they were made aware of by way of the customer retreating back to their establishment.  The case the expert testified in for us six months ago had five previous robberies.  We knew he had just made the same argument for us that he was now attempting to say was incorrect.

A little while later, I decided to employ the “cut” method by asking him about the relevance of the crime grids for the property.  He replied that he relies on police reports for the actual property, so I “cut” him with his prior testimony where he relied on grime grids heavily because there were only a handful of police reports for crime on the property.  The difference between the two techniques lies in how you administer the questioning.  The former question was after he revealed his opinions in the case.  The latter questioning was by way of leading him into a trap.  The “cut” technique is accomplished by getting the expert to commit to a particular methodology or particular statement, allowing them to feel comfortable by giving their opinion(s), and then “cutting” them question by question during the deposition with all the contradictory testimony in your possession.

Press Conference: Reaction to Broward Deputy Today Show Interview

Later today, we will once again be honored to stand with our client, Manuel Oliver, the father of 17 year old Parkland mass shooting victim Joaquin Oliver. Only days after the Oliver family accepted the high school graduation diploma for their late son, NBC’s Today Show aired part one of an interview with Former Broward County Sheriff’s Deputy Scot Peterson who was the school resource officer assigned to Marjory Stoneman Douglas High School on the day a gun killed 17 people and injured 17 more.

Today’s press conference with Mr. Oliver will be to give reaction to that NBC network television interview.  click to watch Today Show interview

Press Conference Details

What: Press Conference to respond to part one of Today Show Interview with FMR BSO Deputy Scot Peterson

When: 12 pm – Today – June 5th, 2018

Location: Beyond Group (office) 98 NW 39th Street, Miami, FL 33127

Who: Manuel Oliver and Haggard Law Trial Attorney Christopher Marlowe

Media Contact: J.P. Hervis, Brandstory Communications, 305.321.4293 Jp@brandstorycommunications.com

 

The Nuts And Bolts of Negligent Security Cases

The Nuts And Bolts of Negligent Security Cases

By: Michael Haggard  (Bio) and Christopher Marlowe (Bio), The Haggard Law Firm

Negligent security cases are time consuming, very costly, require a hyper attention to detail, a team effort and knowledge of foreseeability, and in many cases criminal law and a ‘typical’ negligent security case does not and will not ever exist. Our firm has handled hundreds of these cases over the years and have obtained more than $400 million in results for our clients. We can most affirmatively say the immense challenges of these cases are outweighed by the results that can help bring justice to a victim or family that the criminal justice system may never be able to provide, while also changing the way a business or entire industry operates.

In a wrongful death car accident case, we all know to preserve evidence, request the relevant reports, statements and traffic homicide reports.  We contact the witnesses tied to this particular moment in time, hound law enforcement and medical examiners to make sure we have all evidence tied to the incident, and begin working these pieces into the theory we hope will increase the probability of success at the end of the case.  While this basic and incomplete framework is an important part of a negligent security case as well, it does not account for the historical analysis necessary to place the subject incident in the perspective necessary to appreciate which theory is best, and why. 

Power of Foreseeability: $100 million verdict

Like any of the most complicated areas of practice there are multiple layers to consider when litigating a negligent security case.  Foreseeability of the act in question, most often a crime, is the first element of the case to consider. For example, it is good to know whether a particular shooting or sexual assault occurred in the common area of an apartment complex, over which the owner or manager had exclusive control.  It is important to know whether there is a history of any such activity upon the Premises, and in the areas adjacent or related thereto. There is a history of cases where the Plaintiff counsel assumes that because the crime does not appear to be a “hit” and because the crime on the property is “bad” that their case is a winner.  Some of the most common arguments by defense council are tied to the character of the victim or because the area may have a high crime rate there isn’t much the property owner could have done to stop the incident that caused the death or harm of your client. In most states, neither argument has much merit because of the statutes that lay out the responsibility of the property owner to take reasonable measures to protect all guests, residents or customers on a commercial property from harm. In November 2007, we successfully obtained a $102.7 million verdict in a negligent security shooting case thought to be the largest verdict of its kind in the country. We represented a patron of an exotic dance club.  Our client sat waiting in his car for his friend to return from retrieving his wallet when he was approached by an unknown person who attempted to rob him at gunpoint. The assailant shot our young client. The bullets rendered him a ventilator-dependent quadriplegic.  The jury found that the strip mall where the club was located did not have sufficient security, as there was only one guard on duty. The strip mall’s ownership admitted they had never spent one dollar on security or safety despite the fact there were 26 violent crimes on the same property during the seven years prior to the shooting of our client.  Video on Case

 

Injured or lost a love one on the property of a business, apartment complex or hotel? We want to hear your story, click here or call 305.446.5700

 

Full Speed Investigation

Continue reading “The Nuts And Bolts of Negligent Security Cases”

$3 Million Negligent Security Case Result for Gunshot Victim

Miami Dade County, FL – A gunshot victim who had his kidney, portions of his intestines removed and his colon perforated settles a negligent security lawsuit against northwest Miami apartment complex for $3 million.

 

On May 3rd, 2014, Dennis Gore and his friend worked together cleaning one of their clients’ business’. After work, Dennis and his friend played flag football and then went to Dennis’ mother’s apartment at Suncoast Apartments (999 NE 167th Street). Dennis would ask his friend to take him to Walgreen’s to get an ace bandage because of a sore knee.

The two of them went downstairs to Dennis’s friend’s car in the parking lot when Dennis realized that he left his wallet upstairs.  He told his friend to meet him around the other side off 10th avenue while Dennis went back upstairs to get his wallet.  After retrieving his wallet, he took the stairs to a door led directly into the parking lot when his friend to pick him up.

 

A man standing at the bottom of those stairs simply said “hey”, which made Dennis turn around. The man was brandishing a gun. Dennis attempted to evade the stranger but was met by a second man who tried to grab him. After breaking free and attempting to exit through a doorway, bullets began to fly.  He was shot 6 times. Dennis was taken to Jackson Memorial Hospital where he went into emergency surgery.

Haggard Law Trial Attorney Jason Brenner – CONTACT BRENNER – JRB@haggadlawfirm.com 

Haggard Law Firm Trial attorney Jason Brenner and Douglas McCarron litigated the case. Brenner says while the apartment complex did have security in place, it was not sufficient considering the level of crime in the area. The claims made in the case were past and future medical expenses and past and future pain and suffering. “May 3rd was the beginning of a nightmare that Mr. Gore will never wake up from and it may have been prevented if this apartment complex had fully committed to providing the level of security needed to protect residents and guests.”

Haggard Law Trial Attorney Douglas McCarron – CONTACT MCCARRON – DJM@haggardlawfirm.com 

 

The Haggard Law Firm has an extensive history of litigating negligent security cases involving apartment complexes, hotels, motels, gas stations and other commercial businesses. Over the last ten years, Haggard Law Trial Attorneys have obtained more than $400 million in results for clients severely injured or the families of those killed due to a property owner or managers negligence.

CONTACT HAGGARD LAW FIRM 305.446.5700

VIDEO: What is the first step in a negligent security case??

 

 

 

Press Conference Regarding Parkland Shooting

MEDIA CONFERENCE ALERT

Attorneys Representing Parkland Shooting Victims’ Families To Hold Media Conference, Will Be Joined by Parents of Shooting Victim Joaquin Oliver

 

Ft. Lauderdale, FL – In response to court records that indicate the Broward County School Board aims to minimize its responsibility in the shooting deaths of 17 people at Stoneman Douglas High School in Parkland Florida February 14th, a press conference will be held on Friday, April 27th, 2018 at 10:30 am outside the Broward County School Board building.

 

According to the South Florida Sun-Sentinel (click to review article ), court records show that The School Board “is portraying the mass murder as one incident with many victims.” Michael Haggard and Todd Michaels of The Haggard Law Firm, which represents the families of two victims, will be joined by 17-year-old victim Joaquin Oliver’s parents Manuel and Patricia.

 

Trial attorney Michael Haggard of The Haggard Law Firm says “the school board is watching its financial best interest instead of that of the families it has publicly claimed it would continuously support.” Haggard, whose law firm represents the Oliver family in this case, adds “The School Board should be ashamed. Each of these families are suffering. We have successfully litigated against School Boards in the past and will take this matter to Tallahassee if needed.”

 

The Haggard Law Firm represented the family of Juan Carlos Rivera, who was stabbed to death at Coral Gables High School in September of 2009. In that case, Haggard filed a claims bill in the State Legislature to finalize the $1,875,000 settlement agreed upon with the Miami-Dade County School Board.

 

Media Conference Details

 

Haggard Law Firm and Negligent Security Cases

The Haggard Law Firm has litigated nearly 200 cases involving the failure to provide adequate security resulting in the victim suffering severe injuries and/or death. Since 2007,  The Firm has handled over 175 negligent security cases and delivered over $400million in verdicts and settlements in those cases.

 

Establishments such as bars, restaurants, flea markets, shopping centers, nursing homes, banks, hotels and apartment buildings have all been subjects of successfully litigated negligent security claims. By representing individuals permanently injured in cases stemming from negligent security, we take an active role in making the community safe for the public.

 

In 2017 and 2016 TopVerdict named two different Haggard Law Firm cases as the #1 inadequate security (negligent security) verdicts in Florida each respective year.

Learn more about Haggard Law negligent security – inadequate security cases, click here

 

2017 Top Verdict in a Negligent Security Case – Haggard Law Firm

The Haggard Law Firm has been recognized by TopVerdict for notable results in 2017. TopVerdict recognizes U.S. law firms and attorneys who have obtained one of the highest jury verdicts, settlements, court or arbitration awards in the Nation or an individual State, in a particular area of law, and year

The $12 million verdict obtained by Haggard Law in Machado v Waves of Hialeah was named by TopVerdict as the number one inadequate security (negligent security) verdict and third highest premises liability verdict in Florida in 2017. The negligent security, wrongful death case was litigated by our Christopher Marlowe, Jason Brenner, James Blecke and co-counsel Alexis Izquierdo, ESQ.

Click here to view multiple media reports on the Machado verdict. 

The Machado case was also named one of the Top 50 Verdicts overall in Florida in 2017.

This is the second straight year Haggard Law has earned the #1 Inadequate Security verdict recognition. In 2016, Brenner and trial attorney Douglas McCarron were recognized for the $1.7 million verdict obtained in Navas V Regal  Entertainment Group. That case involved injuries suffered by a Monica Navas after moviegoers trampled her while trying to frantically escape a theater after a suspicious person started a fight days after the Aurora Colorado movie theater mass shooting.

Christopher Marlowe and trial attorney Pedro Echarte were the litigators of the #3 ranked inadequate security case on the 2017 list. The pair delivered a $1 million result in Gilbert v. Cryptical Development LLC.

 

Continue reading “2017 Top Verdict in a Negligent Security Case – Haggard Law Firm”

$907K Verdict in Waffle House Parking Lot Beating Case

Late Friday, a Ft. Myers jury awarded long haul trucker Steve Long $907, 211 for the injuries he sustained from a 2014 beating by several people in the parking lot of a Waffle House.

The Haggard Law Firm’s Todd Michaels co-counseled the negligent security case along with Dave Mishael of the Law Offices of David B. Mishael and Steven N. Kassner  of Steven N. Kassner, PA.

The team of attorneys explained to the jury that for the 3 years before Long was attacked on April 19, 2014, , there were 24 significant crimes committed on the property. Those crimes included multiple fights (one involving nearly 100 people) and three incidents involving gun shots.

Haggard Law’s Todd Michaels explains “all of the crime and danger occurred in the 3rd shift, nonetheless, there was nothing done about it, IE: no security in the parking lot, no outside security cameras, poor lighting and no manned security.” 

 

 (Scroll down to watch video RE: importance of Foreseeability in Negligent Security Cases)

Continue reading “$907K Verdict in Waffle House Parking Lot Beating Case”

I Became a Trial Lawyer Because…

Michael Haggard says he wanted to become a trial lawyer thanks to the example set by his father Andy Haggard and what he watched his father do to help clients effected by tragedy.

 

 

 

Haggard has established himself as a powerful force in the South Florida Legal Community as the Managing Partner for The Haggard Law Firm. After spending time as a Public Defender and working with a small personal injury firm before joining The Haggard Law Firm, Haggard was named a partner in 2001, secure in the belief that every case holds equal importance and could mean the opportunity to award a family resolution to a devastating incident.

 

TO CONTACT MICHAEL A. HAGGARD, CLICK HERE MAH@HAGGARDLAWFIRM.COM OR CALL 305.446.5700

 

He soon captured national headlines as the only plaintiff’s personal injury attorney to secure three separate $100 million dollar verdicts on behalf of individual clients. Haggard secured two consecutive $100 million verdicts on behalf of children involved in pool accidents. Several years later, a third $100 million verdict was awarded by a jury in a negligent security case, deemed the largest of its kind for that genre of case law.

to read his full bio click here: http://bit.ly/haggardbiopage