62 Million Verdict

Letter of Appreciation

Letter re: $62 Million Verdict

Mr. Paul Kayfetz
Paul Kayfetz, Inc. Engineering Photography
P.O. Box 310
Bolinas, California 94294

July 30,2002
Re: Randy Ramos, et al vs. Bay, Inc

Dear Paul:

I wanted to take this opportunity to thank you for your excellent work on behalf of the Ramos family. I am convinced that we would not have gotten the same jury verdict without your help. We had tried this case to verdict once before and wound up with a disappointing result. We were granted a new trial and decided to add expert witnesses in a few areas of the case in order to rebut some of the defense positions. One of the best decisions I made in the case was to bring you on board.

In the first trial the defense used both a computer animation and a nighttime visibility demonstration to try to blame the drivers. The technical analysis you and Jorge performed was amazing. You showed how the defendant had fudged the facts and inputs in order to get the result they wanted. Truly a case of garbage in garbage out. Your analysis of the animation was so convincing the defendant never offered it in the second trial. Your analysis of the purported nighttime visibility demonstration showed it was so flawed the defendant did not attempt to offer a majority of the demonstration. Your help was instrumental in our successful Daubert challenge to the remainder of the demonstration. The defense had probably spent over $100,000 on these demonstrations and none of it got in front of the jury.

The Court agreed with the jury verdict and has now entered judgement for $62,197,883. The Judge recently overruled the defense motions to set aside the verdict, reduce the verdict, or grant a new trial. I will keep you informed of any developments while the case is on appeal.

Once again, on behalf on the Ramos family and my fellow plaintiffs counsel I want to thank you for the excellent work. We couldn’t have done it without you.

Very truly yours,

Steve T. Hastings
Hastings and Alfaro
Suite 420
101 No. Shorelinw
Corpus Christi, Tx.