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Kenneth Vercammen & Associates
A Law Office with Experienced Attorneys for Your New Jersey Legal Needs

2053 Woodbridge Ave.
Edison NJ 08817

Personal Injury and Criminal
on Weekends 732-261-4005

Princeton Area
68 South Main St.
Cranbury, NJ 08512
By Appointment Only
Toll Free 800-655-2977

Civil Model Jury Charge 1.22 EXPEDITED JURY TRIALS

Civil Model Jury Charge 1.22 EXPEDITED JURY TRIALS

An expedited jury trial is a form of summary jury trial conducted pursuant to a consent order which results in a binding and appealable jury decision. It is best suited for cases in which expert witnesses are either unavailable or in which the cost of their testifying is not justified. Its major advantage is that it obviates the need for live expert testimony and allows the case to be presented to a jury based on medical reports and records with limited lay testimony. A more detailed discussion of the procedure and a form of the consent order which is the foundation for the expedited trial can be found in Section VIII of the Civil CDR Bench Manual, Fall 1997. A proposed consent order (available from the Presiding Civil Judge) should be entered into by counsel for all parties before any expedited jury trial begins.

The nature of the expedited jury trial requires revision to some of the model charges. For convenience, all modifications to the model charges required by an expedited jury trial are collected here for easier reference.

Note to Judge:

Preliminary statement to be given before outlining of the order of events in the trial as per Model Charge 1.11(5).

This will be what is known as an expedited jury trial which is a streamlined procedure in which written materials such as doctor reports, medical records, statements from witnesses, recorded pretrial testimony known as depositions may be used in place of live testimony from witnesses. The information contained in these materials and submitted to you for review should be given the same weight and consideration as live testimony given under oath in Court.

Note to Judge:

Alternate Credibility Charge 1.12K for Expedited Jury Trial

In this Expedited Jury Trial, the attorneys have produced evidence in the form of live testimony and also in the form of written materials including [expert reports/statements/records/depositions]. You will have to decide which evidence to believe and which evidence not to believe. Regardless of whether the evidence comes from a lay person or expert, you may believe all of it, only part of it, or none of it.

In deciding what evidence to believe, you may take into consideration:

1. the interest, if any, of the witness or preparer of the written material in the outcome of this case;

2. the accuracy of the recollection of the witness or preparer of the written material;

3. the ability of the witness or preparer of the written material to know what he/she/it is talking about;

4. the reasonableness of the evidence;

5. the demeanor of live witnesses on the stand;

6. the witness candor or evasion;

7. the witness willingness or reluctance to answer;

8. the inherent believability of the evidence;

9. the presence of any inconsistent or contradictory statements.

Note to Judge:

Alternate Expert Testimony Charge 1.15 for Expedited Jury Trial

The evidence in this Expedited Jury Trial includes reports from experts. Generally, witnesses can only present the facts and are not permitted to give opinions. However, an exception to this rule exists in the case of an expert. An expert may give an opinion on a matter in which he or she has (some special knowledge, education, skill, experience or training). An expert may be able to assist you in understanding the evidence in this case or in performing your duties as a fact finder. But I want to emphasize to you that the determination of the facts in this case rests solely with you as jurors.

In this case, the reports of the following experts were marked into evidence and contained certain opinions:

[state the experts names]

In examining the opinions of each expert, you may consider the persons reasons for rendering the opinion(s), if any. You may also consider the qualification of the individual(s) and the believability of the expert(s), including all the considerations that generally apply when you are deciding whether or not to believe a witness testimony.

The weight of the experts opinion depends on the facts on which the expert bases his/her opinion. You as jurors must also decide whether the facts relied upon by the expert actually exist.

Finally, you are not bound by the opinions of an expert. You may give them whatever weight you deem appropriate. You may accept or reject all or part of an experts opinions.

It is for you the jury to resolve any conflicts in the reports of the experts, using the same guidelines in determining credibility that I mentioned earlier.

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Since 1985, KENNETH VERCAMMEN has worked as a personal injury attorney, working for injury victims and their families. By taking a hard-hitting, aggressive approach toward the insurance companies, KENNETH VERCAMMEN and our co-counsel have consistently obtained outstanding results for many injured clients over the years I am proud to have worked on cases in various capacities, small and large. While obviously prior results cannot guarantee the outcome of future cases, I can guarantee that you case will receive the same degree of dedication and hard work that went into each of these prior cases.

In direct contrast to the hard-hitting approach we take toward the insurance companies is the soft approach we take toward our clients. I am proud of my compassionate staff as I am of the outstanding financial results they have achieved. For many years, I have watched them treat our clients with patience, dignity and respect. I would have it no other way.

Many years ago, I attended a seminar sponsored by the American Bar Association on Law Practice Management. This was to help insure that each of our clients is always treated like a person -- not a file! We recognize that you are innocent victims and that you have placed your trust in us. Please understand that we understand what you are going through. Feel comforted that we are here to help you.

If you retain KENNETH VERCAMMEN to represent you, we will give you the same advice we give each of our clients -- concentrate on your life, you family and your health. We will take care of everything else. Leave all of the work and worry about your legal rights to us. Trust us. Believe in us. Have faith in us as your attorneys. Understand that we will always to do what we believe is best for you and your case. Helping you is our job. In fact, it is our only job -- guiding injury victims like you through one of the most difficult times of your lives, with care and concern -- while fighting aggressively to the limits of the law to obtain compensation and justice for each of you!

Print our Personal Injury Questionnaire on our Website, Fill it out and Fax back, so we can determine if we can help you obtain an injury settlement. We would welcome an opportunity to prove to you what we have proven to thousands of injured clients -- that you can feel comfortable and secure in the fact that KENNETH VERCAMMEN - Trial Attorney We Fight To Win.

When you have been injured in an accident or collision, you are worried about who is going to pay your medical bills, lost wages, and other damages. The last thing you want is to be taken advantage of by an insurance company. If you dont protect your rights, you may not be able to make a claim.

Insurance companies have attorneys and adjusters whose goal is to pay you as little as they can. You need a New Jersey personal injury lawyer to fight for you. I am dedicated to helping your recover as much money as possible under the law.

You need an attorney who will work hard to protect your rights, maximize your insurance settlement and minimize the hassles of dealing with the insurance companies. You need an experienced and aggressive New Jersey trial lawyer with PROVEN RESULTS who will fight for you. Having an experienced personal injury lawyer can make the difference between getting what you deserve and getting nothing.

Without the threat of a lawyer who is willing to go to trial and seek a big jury verdict, why would an insurance company pay you what your claim is really worth? Lawsuits can be expensive, and many people do not have the money to pursue their claim. In every case, I advance all costs associated with pursuing your case and I do not ask you for a penny until we recover from the other side.

I am an experienced aggressive trial lawyer and a 3rd degree Black Belt. I am not afraid to take your case to trial if that is what it takes to maximize the amount of money your recover for your personal injury. I offer one-on-one service, and I will not hand your case off to an inexperienced lawyer or a paralegal.

Reduce the stress of making a claim.

Personal injury accidents can turn your life upside down. Making a personal injury claim can be difficult and time consuming. Once I take your case, you can stop worrying about dealing with the insurance companies and focus on recovering from your injuries. I take care of all of the paperwork, phone calls, and negotiations, so you can get on with your life.

p.s. For those clients who are afraid or reluctant to go to Court, KENNETH VERCAMMEN also offers a special -- For Settlement Only -- program. This means that if we are unable to settle with the insurance company, we will not go any further -- unless you want us to. You have my personal assurance that there will be absolutely no pressure and no obligation.

We handle personal injury cases on a contingency fee basis.


Call our office to schedule a "confidential" appointment 732-572-0500

Kenneth A. Vercammen is the Managing Attorney at Kenneth Vercammen & Associates in Edison, NJ. He is a New Jersey trial attorney has devoted a substantial portion of his professional time to the preparation and trial of litigated matters. He has appeared in Courts throughout New Jersey each week on personal injury matters, Criminal /Municipal Court trials, and contested Probate hearings.

Mr. Vercammen has published over 125 legal articles in national and New Jersey publications on criminal, elder law, probate and litigation topics. He is a highly regarded lecturer on litigation issues for the American Bar Association, NJ ICLE, New Jersey State Bar Association and Middlesex County Bar Association. His articles have been published in noted publications included New Jersey Law Journal, ABA Law Practice Management Magazine, and New Jersey Lawyer. He is the Editor in Chief of the American Bar Association Tort and Insurance Committee Newsletter.

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