
Our client was a guest at a major hotel in Miami-Dade County when he was violently attacked on the property. The assault left him with a severe open head wound requiring multiple stitches and a traumatic brain injury with lasting consequences -- including loss of consciousness, memory loss, chronic headaches, and a range of debilitating neurological symptoms.The hotel had contracted with a private security company to protect guests on the property. That security presence failed. Rather than intervening or calling law enforcement when a situation escalated, the on-site security guard became directly involved -- and our client paid the price with a serious head injury.This case went to trial twice. The first trial ended in a mistrial due to juror hardship. The second trial also ended in a mistrial -- this time because defense counsel engaged in deliberate misconduct during cross-examination of our client, injecting irrelevant and highly prejudicial information before the jury. The court granted an immediate mistrial and our firm filed a Motion for Sanctions.Facing a third trial, mounting sanctions exposure, and a liability admission on record from their own security guard captured on video deposition, the defendants resolved the case for $500,000.
We exposed the security failure on the record. The hotel's contracted security guard gave video deposition testimony that was devastating to the defense. She admitted on camera that her protocol required calling 911 when a situation escalated -- and that she failed to do so. The trial court ruled this testimony admissible over defense objection.We turned defense misconduct into leverage. When defense counsel attempted to ambush our client on the stand with a decade-old, irrelevant reference to a prior hospitalization, the court immediately declared a mistrial. Our firm filed a Motion for Sanctions the same day, seeking over $100,000 in combined attorney's fees and costs.We held the line through a difficult case. Our client had prior history the defense intended to use against him. We anticipated those attacks, prepared accordingly, and kept the focus where it belonged: on the hotel's failure to provide adequate security.
