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Continued... Page 4 > Story Boards

It is also important for the lawyer to obtain all photographs taken of the scene by either police agencies, state or federal occupational safety and health agencies, worker's compensation or insurance adjusters. Check all available sources of photographs before you consult the artist. For example, in Pattison v. Harmon-McCloud Const. Co. , we found crucial photographs of the scene of a construction site just prior to plaintiff's accident in the files of the bank funding the project. A bank inspector had gone to the scene on a periodic basis and recorded construction progress in numerous pictures.

If all available sources of photographs are not satisfactory, which is often the case, the lawyer must then visit the scene of an accident with the client and take photographs of every important angle that the artist may need. It is better to be overinclusive and shoot everything.

It is also helpful for the lawyer to take a portable video camera and interview the client about the circumstances of the accident at the scene. Obviously this approach is useful only for certain types of cases, involving trauma or collision. It would not be useful in the case of medical malpractice. However, if the client is interviewed at the scene in an appropriate case, the resulting videotape can quickly impart the necessary information to the storyboard artist.

All reports and documentation, as well as interrogatory answers should also be sent to the storyboard artist. While this can be a great deal of trouble, it is necessary to laying a proper foundation. The artist should also consult with any other liability experts so that the final storyboards have the stamp of approval of all major witnesses in the case. Close communication between the artist and the other experts in the case minimizes the chance that the storyboards will be excluded from evidence through a divide and conquer strategy by the opposition.

Once the artist has all the photographs and other background materials, he/she then isolates the key units of action on either liability or damages and prepares rough sketches. The sketches are then given to the client and the experts for preliminary review, and feedback is sought as to their accuracy. Then the artist incorporates any changes and prepares a more finished product. Once again, this is reviewed by the necessary witnesses and any changes made. By adhering to this process, the final storyboards are solidly based on the available evidence and will be admissible in trial.

Storyboards prepared with the necessary foundation were admitted in Norris v. State . In that case, a motorcycle rider was injured when he struck an unmarked curb adjacent to a freeway on-ramp.

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