Family of Local Librarian
Murdered in ATM Robbery to Announce Negligent Security Lawsuit Against Credit
Reward For Information
Leading to Killer(s) Increases to $23,000
Miami Gardens, Fla - The family of Jaime Humet, who was killed on December
10th, 2018 while leaving the ATM of the Dade County Federal Credit Union
located at 20645 NW 2nd Avenue in Miami Gardens, says the business did not have
sufficient security measures in place to prevent the tragedy that claimed the
life of their beloved Jaime.
Humet’s mother Pilar and
brother Nick will be joined by their attorneys Pedro Echarte of The Haggard Law
Firm and Angel Diaz of Kirschner, Groff & Diaz...
How Safe Is the Apartment You Want to Rent? Key Questions to Ask a Landlord Before Signing a Lease
A sense of security and safety for you and your family is key to making a house feel like a home.
Unfortunately, many landlords don’t provide, and in some cases aren’t legally required to share, crime and safety information to a potential tenant.
“Along with costs and amenities, tenants should be prepared to ask a variety of questions about safety measures before signing a lease and moving into a new apartment or home” says Michael Haggard. Haggard is the Managing Partner of The Haggard Law Firm (www.haggardlawfirm.com) which has made a mark successfully representing tenants who are injured or killed by someone committing a crime that could have been prevented if the landlord of the property where the crime occurs had taken proper security measures.
of Victims to Discuss New Lawsuits Against Miami -Dade County School Board On
Behalf of Teenagers Sexually Assaulted By Middle School Teacher
This is the first time these mothers have spoken out.
Miami, FL - A lawsuit was recently filed against the School Board of Miami-Dade County on behalf of a teenage female victim (Jane Doe) who was sexually assaulted by former Brownsville Middle School physical education teacher Wendell Nibbs.
Beginning in her 6th grade school
year and continuing through the end of her 8th grade school year at Brownsville
Middle (2013 through 2016), Nibbs sexually harassed, sexually assaulted
and raped Jane Doe. The assaults and rape occurred...
Press Conference Scheduled 12/18/18
Mother of a 12 Year Old Murdered By a Convicted Sex Offender Says Owners/Managers of an Apartment Complex Could Have Prevented the Tragedy
Pensacola, FL - Shantara Hurry, the mother of 12-year-old Naomi Jones, who police say was murdered by convicted sex offender Robert Howard in 2017, is filing a negligent security lawsuit against those responsible for the apartment complex where her daughter was kidnapped.
Jones went missing from her apartment located at 1460 E. Johnson Avenue in Pensacola, Florida on May 31, 2017. The disappearance captivated and mobilized the community to find Naomi. Her remains were eventually found...
According to a report by the South Florida Sun-Sentinel, employees at Marjory Stoneman Douglas High School were “tragically unprepared” to best protect students on the day of the mass shooting that killed 17 people and injured 17 others. The newspapers reports that the lack of preparation was due to “inadequate training and unclear procedures in the school district.”
The lack of a coherent, uniform policy is one of the major failures identified by a state commission investigating the Feb. 14 massacre.
The paper learned that district officials were unsure as to whether a “Code Red” meant an “active killer”. It does not.
Haggard Law Firm trial lawyer Pedro Echarte has finalized the terms of a $1 million settlement in a negligent security/wrongful death case where the victim was the father of five.
Haggard Law represented the plaintiff’s decedent who was murdered in an attempted armed robbery while speaking on the phone outside of his apartment complex in Pompano Beach, Florida on January 31 of 2017. Liability centered around the apartment complex’s lack of security measures at the apartment (including, but not limited to, inadequate lighting, lack of surveillance cameras, and lack of access control) despite a history of crime in the surrounding neighborhood. Plaintiff’s decedent left one surviving son here in the United States and a surviving widow in Honduras along with five surviving daughters. The defendant settled for policy limits.
(Pictured Above from Left to Right, Following Thursday’s Verdict: Haggard Law’s Todd Michaels, Champion Legal’s Dan Karanikis, Client Nick Pastor, co-counsel Robert Solomon of Saban and Solomon, Haggard Law’s James Blecke)
Broward County Jury Blames Longtime Las Olas Hotspot for Shooting and Beating of Patron, Orders Business to Pay Victim Nearly $1.2 Million
Ft. Lauderdale, FL – Following a 9 day trial, a Broward County jury agreed that management of longtime Las Olas hotspot Mangos could have prevented the beating and shooting of a man if it had adequate security measures in place. The victim (plaintiff) Nicolas Pastor, was awarded $1.182 Million for the injuries he says altered the course of his life.
The incident occurred March 24, 2012. Pastor was alongside a couple of friends waiting for a table at Mangos in Ft. Lauderdale. The manager of Mangos told the police that night that Pastor was aggressively grabbed by a man inside the restaurant who began viciously beating him along with two other men.
March 24th, 2012 – The scene outside of Mangos Restaurant and Lounge following the beating and shooting of Nick Pastor.
“Mangos had no security and no security procedures to deal with this fight. According to their manager, their only concern was pushing their customer who had been attacked out into the street with his attackers,” says Todd Michaels of The Haggard Law Firm.
Michaels tried and built the case with co-counsel Robert Solomon of Saban and Solomon.
Once the fight was in the street, one of the assailants pulled out a pistol and shot Pastor. The then 32-year-old man was rushed to Broward General Hospital where doctors completed emergency lifesaving procedures including an exploratory laparotomy and a thoracotomy. During the trial, Michaels and Solomon made clear that six years later the attack on their client shattered his life-limiting his ability to work, to sleeping, and restricting his ability to play with his son.
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 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.
Haggard Law Firm trial lawyer and Managing Partner, Michael Haggard email MAH@HaggardLawFirm.com
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.
WE INVITE REFERRAL ATTORNEYS AND CO-COUNSEL TO CONTACT US AT INFO@HAGGARDLAWFIRM.COM or 305.446.5700
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.
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...