$860K Settlement | Motor Vehicle | New York

This case involves a tractor-trailer driver who cared about the wrong things when he chose to back his 48-foot tractor-trailer across traffic and into a motel parking lot where he lived, blocking the oncoming traffic lane of Route 32 entirely, and resulting in a 63-year-old man becoming seriously injured when his Subaru Outback collided with the trailer at full speed (i.e., about 55 MPH).

The event occurred in December 2013, at 7:30 p.m., in Cairo, N.Y. It was dark outside. Just prior to the event, the driver of the tractor-trailer stopped the truck in the middle of the road, facing southbound, with the motel parking lot on his left (i.e., east). He then proceeded to back the trailer into the motel’s parking lot, blocking the northbound lane with the trailer. According to the tractor-trailer driver, there was nobody coming northbound when he started this maneuver, and the trailer had both four-way flashers and reflective tape on it. At the same time, the subject individual was approaching this area northbound on Route 32. The individual recalls seeing bright headlights pointed toward him from the southbound lane, creating a blinding glare, and then he felt as though the headlights were coming toward him in his lane. The man swerved his car to the right, to avoid being hit head-on. He never saw the trailer blocking his lane prior to the impact, and he doesn’t recall if he ever applied the brakes. He states that he does use cruise control often, but he isn’t sure if he was using it at the time of the crash. Just prior to the impact, the tractor-trailer driver says that he flashed his bright lights at the driver to alert him of the truck’s presence, and that the person was “flying” and didn’t slow down. 

Our Mission

Attorney Chris Camastro knew this case wouldn’t be easy, and for that reason he retained TTS for services including a Focus Group to test liability, a Biography to show evidence of damages, and Government Database & Records Searches to investigate prior claims. Additionally, Attorney Camastro hired TTS to attend DME exams with his client to ensure there was no bias or unfairness, and resolve outstanding liens. 

Mr. Camastro invested in the case because he believed his client sustained physical harm by no fault of his own. 

Incident Location

Hear From the Trial Lawyer

“TTS provided me with powerful insights and information throughout litigation. Their services gave me the confidence and reassurance I needed to settle the case.”

Christopher Camastro
Chris Camastro
Trial Attorney

Our Work

Total Trial Solutions worked with our partner attorney for several years on this case. Here is a quick summary of the work we did to assist him. 

Senior Focus Group Moderator, John. A. Kiselak conducted a Focus Group with the purpose of developing  “just can’t get over” facts; to develop case frames; to gauge jurors’ feelings about the tractor-trailer driver from his EBT video; to test the impact of the experts’ reports; to ask the jurors to apportion responsibility for the event; and to uncover any negative attribution towards the plaintiff. 

John gathered information from 12 mock jurors over the course of a 2.5 hour presentation, and used that to draft a 29-page report.  The report armed Attorney Camastro with powerful insights he used to mediate the case. 

Client Biography

The injured party in this case suffered a head injury, therefore Attorney Camastro retained TTS to create a Biography to better understand his injuries. Professional journalist, Sarah Lunham spent hours interviewing the client and his wife, before speaking with former colleagues, friends, and acquaintances. Sarah crafted a “before story” that reflected the individual’s life prior to the date of accident. This part of the Biography focused on the individual’s lifestyle, personality, behavior, goals, interests, and activities, among other things. 

Sarah relied  largely on lay witnesses to tell the “after story” of the subject plaintiff. She used examples and anecdotes from lay witnesses in order to showcase damages like chronic headaches, memory loss,  difficulty with word recall, and inability to focus. 

Sarah submitted a final work product, which included lay witness interview transcripts, witness contact sheets, photos, videos, and much more. 

DME Attendance & Observational Reports

Defense counsel hired a neuropsychologist and an orthopedist to examine this plaintiff and draft a report based on their expert opinions. Attorney Camastro knows this process can be bias and unfair for the plaintiff, and for that reason he hired TTS to attend these exams alongside his client. 

Specialist from TTS attended two neuropsychological exams, in addition to an orthopedic DME with the claimant, and then drafted observational reports for attorney use. The time-stamped reports include all exchanges, both verbal and non-verbal, between the claimant and DME administer. 

These reports put Attorney Camastro inside the exam rooms, and later served as a tool for mediation. 

Research & Investigations

TTS conducted  Social Network Investigations on the plaintiff and defendant to determine what platforms they use to share information online.  Investigators searched social media platforms including, Facebook, Twitter, Instagram, Google, and LinkedIn, and in this case uncovered two significant criminal charges for the defendant. 

Lien Resolution

TTS Lien Resolution Specialist resolved more than $70k in medical liens for this case. The team worked diligently to track and resolve all liens which resulted in faster recovery time.


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