Coral Gables, FL 33134
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Fort Lauderdale, FL 33301
(954) 323-4400
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The Haggard Law Firm’s Todd Michaels, Shelby Walton, and James Blecke earned a $1.32 Million verdict in the negligent security/personal injury case involving Wiley Lowe.
On January 31, 2016, Lowe was a guest at the Elysium Hotel in Ft Lauderdale. Elysium was part of a larger group of hotels known as North Beach Hotels. The hotels were comprised of 15 separate hotels over a 1.5-mile square area.
Continue reading “$1.32 Million Verdict for Injured Model”Haggard Law Firm trial lawyer Christopher Marlowe obtained a $1.69 million settlement in a negligent security case involving the murder of two cousins.
Ken Jean and Bensen Cineas lived on Florida’s southwest coast. They were traveling to an immigration appointment in Miami with a friend late at night, before arriving at a relative’s apartment in North Miami around 3 am. On January 31, 2016, around 4 pm, the cousins were found dead in the front seat of a car. They were found shot in the back of the head, with bullet casings in the back of the car. It is believed that they were dead for approximately twelve hours. Their friend was nowhere to be found.
The apartment complex owned by the defendant, RYAN 15401 6 AVE LLC, had 24-hour security, including a roving patrol. Attorney Marlowe learned during case discovery that the security booth was unmanned for the shift before, during and after the shooting occurred. Security guards testified that they had not been paid regularly for more than a year, and it was common for guards to skip their shifts. Additionally, when the front gate was without a guard, the protocol was to leave the gate open. The gate dedicated for resident use was always broken, so the property was often completely unsecured. No motive was determined for why the victims were shot, or definitively by who.
The Haggard Law Firm has litigated hundreds of negligent security cases for more than two decades obtaining more than $300 million in verdicts and settlements in these cases for our clients.
By Christopher Marlowe, trial lawyer, The Haggard Law Firm
Halloween is one of the more interesting celebrations in the United States and throughout much of the world. For a few hours one night of the year, generally beginning at dusk, children of all ages transform into their favorite ghoul, villain, superhero, princess or idol. They have a license to collect as much candy as the human body could possibly consume in a dizzyingly short period, and will likely go to bed sated on a meal fit for only Willy Wonka.
Continue reading “Safety Steps Property Managers & HOAs Should Take This Halloween”
Congratulations to Haggard Law Firm trial lawyer Todd Michaels for being named a Fellow of the Academy of Florida Trial Lawyers. The Florida Justice Association’s Fellows program recognizes individual accomplishments as a trial lawyer and contributions to the mission of the FJA. Michaels was voted into the exclusive and distinguished program by his peers.
To qualify, members of the Fellows program must be past presidents of the Florida Justice Association, a current voting member,a board member for at least 5 years, a recipient of the Crystal EAGLE Award, and an Eagle Patron.
About Florida Justice Association
The Florida Justice Association (FJA), formerly the Academy of Florida Trial Lawyers (AFTL), is dedicated to strengthening and upholding Florida’s civil justice system and protecting the rights of Florida’s citizens and consumers.
FJA works in the legislative, political and public arenas to ensure that Floridians know and understand the importance of their rights to justice and to make certain that these rights, which are at the very core of what it means to be American, are safeguarded and protected.
Todd Michaels Bio
Todd Michaels Esq, a lifelong Miami-Dade resident, joined The Haggard Law Firm in 2009. In May 2014, he was named partner at the firm. Todd handles a wide array of the firm’s cases involving wrongful death and catastrophic personal injury, representing clients who were injured through the negligence of others. His practice primarily involves negligent security throughout the State of Florida and nationwide. Todd has been a frequent speaker on various aspects of negligent security law to different Legal and Security industry groups throughout the country, and has had articles relating to negligent security cases published. Click to read full bio
VIDEO
Michaels discusses how trial lawyers must always be focused on trial, not a settlement.
By Michael Haggard and Todd Michaels, The Haggard Law Firm
Every trial lawyer understands the significance of creating and developing a strong, clear theme for their case at trial. The theme of your case initiates a tone towards your Case-in-Chief and if powerful enough, it will dictate which fork in the road, favorable or unfavorable to your client, the jury takes.
Opening Statements
Opening statement is the second opportunity the trial lawyer has to begin planting the seed of bias in favor of his or her client—seasoned and skilled trial lawyers understand voir dire is really the first opportunity. It is critical to communicate to the jury and ingrain within each member of the jury a persuasive and powerful theme. Why? Once your theme is etched into the minds of the jury, each juror will begin to look for evidence that supports that theme. If a particular piece of evidence contradicts that theme they will likely discard that piece of evidence or they may not associate as much credence with it as they would have had it fit with your theme. This is vital to the outcome of your case. The theme essentially summarizes your case for the jury. Whether it is a short phrase or one word, the theme should capture the case theory, tone and the area of focus for the jury. The theme should be simple and easy to understand. I can share with you a case example in a recent trial of The Haggard Law Firm—the case of Trinard Snell.
Our firm tried the negligent security case against a gas station owner and operator, which resulted in a $5.7 million dollar verdict on behalf of the deceased Plaintiff and his survivors. Understanding the importance of a clear theory and a memorable, persuasive theme, we began opening statement with our theme— inadequate security on a crime-ridden property.
The case theme was presented to the jury at the very beginning of opening statement, repeated throughout the entire opening statement and reiterated at the end. Why? A concept in psychology—primacy, and recency—tells us that order is important! The primacy effect is described as the ability of an individual to recall information better that was presented earlier rather than later. The recency effect is described as the ability of an individual to remember information presented most recently to them better than information that was presented earlier. When you combine the two, optimal information recollection is achieved. Therefore, at minimum, the jury must here your theme at the beginning and at the end of your presentation.
Testimony and Evidence Presented
After your jury has been indoctrinated with the theme of your case through voir dire and opening statement, you must keep the jury on that same track during the presentation of the oral testimony and physical evidence. Depending on the length of the trial, the jury will hear days to weeks of testimony. It is their job to sort through the evidence presented and make a just decision at the end of the trial. After weeks of testimony, jurors often become overwhelmed with the volume of information and evidence presented. It is the trial lawyer’s job to organize this testimony and evidence presented to the jury in a manner that diminishes this information overload. I use the analogy of a train on a train track to best describe this concept. The theme is the locomotive. Your jury represents the passengers on the train. The trial lawyer must keep his or her passengers onboard throughout the entire trial until arriving at destination “Favorable Verdict.”
One way to ensure your train passengers are not disembarking is to reiterate your theme and theory of your case throughout each segment of the trial. Your theme should be clear, concise and easy to recognize. The theme is the lens through which your jury will view the case. It is imperative that the lens you provide to the jury is the correct diopter—representing a powerful and persuasive theme. An incorrect diopter will result in a hazy, unclear view of your case and perhaps an unfavorable verdict. Mock trials and jury focus groups are a great way to gauge the lens diopter your jury will need.
As simple as this may sound, many lawyers have a difficult time successfully implementing these techniques. Through our years of law school and demanding casework at our prosperous law firms, our legal minds are trained to analyze the complexities and minutiae of the law, creating sophisticated legal arguments for opposing counsel and the court. The basic techniques of persuasive communication are often neglected due to the lawyer’s engrossment with the complexities of the legal issues of their case and their own familiarity with legal terms and attitude of simplicity. For example, the trial attorney that uses the theme of “Negligent Actions” will be rudely surprised by the jurors’ varying definitions of negligence. Despite the lawyer’s familiarity with the term “negligence” and its rudimentary elements, it is not so easily nor correctly defined by the jury. Through juror focus groups and mock trials, the lawyer can clear out the fog and rework the case theme prior to trial. During the deliberations at mock trials, I often hear jurors begin an explanation with “Personally, I feel that…” or “To me, this means…” These phrases are indicative of “information gap-filling.” Jurors will pull from their personal experiences to fill in the gaps. Those gaps are either areas where the jury is confused or has simply forgotten the information presented. Regardless of the reason for the existence of the gap, the juror will instinctively try to fill that gap in order to make sense of the legal questions they are tasked with answering. This illustrates why trial lawyers cannot forget the basics and cannot neglect the importance of simplifying and effectively communicating those complex issues to the members of the jury. The skilled trial lawyer will be mindful of this. The skilled trial lawyer will have an engaging theme.
Nuances of the Case Theme
Continue reading “Case Themes – Jury Selection Through Closing Argument”
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”
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 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.”
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.
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
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.
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”
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”
The Haggard Law Firm, P.A. represents the rights of people seriously injured or killed through the fault of others. We are passionately committed to our clients and stress the highest level of personal service, professionalism and case preparation.
