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Client  Correspondence  re  Paul Kayfetz


I was authorized to retain Paul Kayfetz, the very best photographic reconstructionist available, to assist in the defense of this dangerous case involving a brain damaged young girl. As a personal favor to me, Mr. Kayfetz agreed to drop other matters and schedule his work in advance of the final mediation session before depositions of expert witnesses was to begin. The idea being that we could avoid taking the depositions of a huge number of expert witnesses if the case could be settled. Mr. Kayfetz scheduled the work as requested, produced outstanding photographs of the visibility of the approaching van from plaintiff's perspective, and we used those photographs effectively at the mediations to get plaintiff's attorney to accept what we regarded as a reasonable settlement figure. During an unguarded moment, plaintiff's attorney conceded to me that his photographic reconstructionist was a poor second to Mr. Kayfetz, both as a photographer and as a witness testifying in court.
Weldon S. Wood, Esq. Robinson & Wood November 30, 1999

Mr. Kayfetz is the engineering photographer who was responsible for the staging and filming of the visibility study during the night of September 22 and early morning of September 23. His crew was responsible for obtaining the police support for the road closures, setting the sensors on the roadway and sidewalks that allowed filming to proceed at the vehicle and pedestrian speeds established in discovery, and rigging the equipment necessary to produce the rainfall. In our opinion, the visibility study ultimately led plaintiffs to settle this case at a figure considerably below all of the demands pending in the month before trial. All plaintiffs originally made a joint demand to resolve the case for $10 million during the first week of September. In the course of the mandatory settlement conference on September 16, plaintiffs originally made a joint policy limits demand of $5 million, then raised their individual demands to $3.25 million for the (orphan) plaintiffs and $3.5 million for (the brain-damaged pedestrian), for a total of $6.75 million. That demand stood until the mediation on September 24, when the (orphan) plaintiffs settled for $1.1 million and (the brain-damaged pedestrian) settled for roughly $1,365,000.00.
John Koeppel, Esq. Ropers & Majeski October 4, 1999

I always enjoy being able to relay good news! In this case, the good news is that we received a defense verdict at the jury trial in this matter. This was a case in which we were not guaranteed a defense verdict. We hoped to show with your motion picture that other drivers who were stopped in all lanes of Westbound I-80 had some responsibility for this accident. After the trial, I spoke with the jury foreperson who told me that the motion picture showed him that if the other drivers had set out hazard triangles, the triangles would have been visible to our driver. This confirmed for me that the motion picture had the desired effect. Months prior to trial, we made a Code of Civil Procedure 998 offer in the amount of $329,000. The plaintiff rejected the offer and countered with her own offer of $600,000. Since we received a better verdict at trial, we are now entitled to our costs. This includes the complete cost of the motion picture.
Catharine A. Ching May 19, 1999

Thank you for your excellent work on the crane accident video and animation. It was excellent, and was an incontrovertible piece of demonstrative evidence showing that the accident could not have occurred in accordance with plaintiff's theory. This was invaluable in settling the case at a reasonable price ?from a $2.5 million demand to a $450,000 settlement, or essentially plaintiff's wage loss. While we likely would have prevailed at trial, a 1% finding of fault would have made our client liable for 100% of these economic damages.
I also wish to thank your crew for their professionalism and attention to detail throughout. You were all put "under the gun" as we approached trial, and were able to put together a very effective production that a jury would have much appreciated.
[See "Computer and Video" pages.]
Mark J. Rice February 25, 1999

I provided copies, and, of course, explained what the film and photographs showed. At that point the plaintiff's counsel decided to fold up his tent and go home. This case was settled for a total of $50,000, based on over $145,000 in medical specials alone. The previous demand had been for $1.0 million, which was the full limit of the insurance policy. I like to think that a lot of the credit for settling the case at the amount we did goes to you and to Richard Stuart. Your work, and the beautiful product that you and Richard developed, gave me the confidence to approach this matter very aggressively and which eventually resulted in what I consider to be an excellent settlement.
Thomas S. Brazier June 17, 1996

I want to thank you for all of your efforts in the successful prosecution of this matter. The jury verdict was due in no small part to your efforts in producing the movie film shown to the jury. It is my belief that without the movie film we would not have been able to successfully prove liability and rebut the defense arguments regarding contributory negligence. Your willingness to assist me during this matter and to help in the questioning of the adverse witnesses was most appreciated. I very much enjoyed working with you and look forward to doing so in future matters.
Michael R. Mordaunt; Diehl, Steinheimer, Riggio, Haydel & Mordaunt; September 24, 1993

The above-entitled case has settled. Without your input, Southern Pacific Transportation Company would not have been in as good a position as it was to resolve this lawsuit.
Vivian Raits Solomon; Lane, Powell, Spears & Lubersky; June 2, 1993

Again, thank you for your hard work. We obtained a gross judgment of 5.3 million dollars. We could not have done it without the significant contributions by you.
Kerry M. Gough May 28, 1993

The film demonstrated beyond argument that the train crew had a clear view of the demonstrators on the tracks ahead, had ample time and opportunity to stop, and did not do so ?completely debunking the defendants' claims to the contrary. Serious settlement discussions began for the first time within a few weeks of the film's first being provided to defendants. The case settled for nearly $1 million.
Thomas Steel; February 3, 1992; [Writing to California Lawyer magazine. See "Article" page.]

It is in large part due to your excellent efforts as an expert in this case that we have been able to resolve the matter out of court.
Kathryn Shubik Diemer January 3, 1991

Thank you very much for your multi-faceted and expert assistance in this matter. Your quality work has undoubtedly facilitated an expeditious and equitable resolution. Additionally, it was a personal and professional pleasure to work with you during the visibility video tape created last June.
Lawrence R. Cohen March 21, 1990

Thanks to your great help in this case, we were able to get the matter settled the day before the trial was scheduled to commence in the Napa County Superior Court. We came out of the settlement extremely well and the plaintiff's attorney got a little more than his costs out of the settlement, which we consider a real victory.
Stuart M. Gordon; Gordon & Rees; January 18, 1984

This is just a note to thank you for your excellent help and thoroughly professional work in our recent trial. Both the court and the jury were completely impressed. The jury was only out a little over an hour before returning a complete defense verdict.
Thanks again, and I look forward to working with you on the next one.
E. D. Bronson; Bronson, Bronson & McKinnon; December 7, 1982

The State was found to be not negligent, so the State does not need to pay any money to Plaintiff.
Thanks a lot for your help. The film played a significant role in the jury's deliberation.
Charles F. Fell, Deputy Attorney General October 1, 1982

We would like to take this opportunity to thank you for your excellent efforts put forth in the recently concluded captioned trial in Hilo. Your expertise and cooperation were of the highest order, and we really appreciated your efforts. We have no hesitancy in recommending your expertise in engineering photography to any of our clients who may require such specialized services. In addition we thank you for complying with the rather demanding trial schedule in Hilo.
Wayne M. Sakai May 10, 1982

The verdict was most satisfying, $728,000 ($3,000 above what I indicated would be a reasonable, high verdict). Further, contributory negligence was kept down to a mere 15% and three jurors didn't want to hold "V" liable at all. I further appreciate the considerations you have given in your fee for the days in which we were not able to place you on the stand. Our check is enclosed with this correspondence.
Salvador A. Liccardo; Caputo, Liccardo et al.; March 1, 1982

Mr. Paul Kayfetz is an attorney who functions as an engineering photographer. Besides dealing with issues such as visibility line of sights and vehicle pathways as derived from photographs of accident scenes, he makes unusually accurate movies and stills of scene visibilities from the viewpoint of drivers involved for presentation at trials. They truly make unique impacts on juries.
Herbert Moskowitz, Ph.D. January 26, 1982

This case has settled, due in large part to the excellent work done by you and Bill Blythe.
Peter Dixon April 2, 1981

Thanks, Paul, for the truly Expert help.
James A. Thompson July 29, 1981

Unquestionably, the nighttime filming of the S-curve was the highlight of my endeavors in the field of forensic proofs. As soon as I am more settled in my new office, I will decorate it with some of the still photos that you had taken.
Leighton K. Oshima, Deputy Attorney General, State of Hawaii; October 21, 1980

As you already know, the Torres case has settled for $40,000. While I feel that this settlement is a good one (considering that the decedent had a wife and two very young children and his estate suffered an economic loss of approximately $300,000 in the opinion of Robert Schultz), it would have been a pleasure to work with you at the trial and to display our forensic proofs.
Prior to your depositions, the Plaintiff's attorney was fairly cavalier about the State's liability being easily established and offered to settle for $200,000. Subsequent to the depositions, his disposition changed drastically undoubtedly because of our preparation and work-up of the case.
Leighton Kim Oshima, Deputy Attorney General; August 28, 1980

I am thankful for your valuable services and assistance in this case. Your advice and analysis was extremely beneficial to us in obtaining a favorable settlement offer from the City and County of San Francisco.
Duane L. Nelson; Damrell, Damrell & Nelson; November 21, 1979