Good evening LMs,

I am seeking guidance regarding a co-defendant EBT tomorrow in a motor vehicle case. By way of general background, the plaintiff alleges that a collision on a New York City parkway resulted in multiple fractures to the non-dominant hand, requiring surgical fixation and subsequent corrective surgery. The plaintiff also alleges permanent deformity, scarring, reduced grip strength, limited range of motion, and ongoing disability, with claimed past and future medical expenses and lost earnings.

I would appreciate any practical guidance on preparing for the co-defendant’s EBT, effective questioning, key areas to focus on regarding liability and damages, common pitfalls, and how best to preserve the record for potential litigation.

Any insights, checklists, or sample questions would be greatly appreciated. Thanks in advance!