By: Donald J. Nolan
Law Offices of Donald J. Nolan
One North LaSalle, 35th floor
Chicago, Illinois 60602
(312) 372-5400
Direct Examination of Dr. Anthony Gamboa
1. Dr. Gamboa, please state your name and professional address for the jury.
2. Dr. Gamboa, what is your occupation?
3. What do you do as a Senior Analyst with Vocational Economics, Inc.?
4. What qualifies you to do this work?
5. Could you tell us about your educational background?
6. Could you briefly describe your previous work history?
7. Have you published any articles in your area of specialization?
8. Please tell us about those articles.
9. Dr. Gamboa, do you hold any special certification within your profession, and if so, please tell us about
that certification.
10. Dr. Gamboa, have you at my request interviewed James Smith?
11. What was the purpose of the interview?
12. Please tell the jury what pertinent information was gained in the interview.
13. Dr. Gamboa, have you reviewed any information provided by me to you?
14. Please identify the information you reviewed.
15. What did you learn about Mr. Smith from reading the information?
16. What effect will reduced reasoning ability have on his ability to perform work and earn money?
17. Dr. Gamboa, I would like you to consider Mr. Smith's age, education, and previous work experience, and tell the jury what type of work he would be capable of performing if he had not sustained a traumatic brain injury.
18. What would be his pre-injury capacity to earn money based on his ability to perform such work?
19. How did you arrive at that figure?
20. Dr. Gamboa, I would like you to consider Mr. Smith's age, education, and previous work experience, and I would like for you to consider also the cognitive limitations that exist for him and state to the jury the type of work that he is presently capable of performing.
21. What is Mr. Smith's present capacity to earn money based on his ability to perform such work?
22. How did you arrive at that figure?
23. Dr. Gamboa, please define worklife expectancy for the jury.
24. Is Mr. Smith's worklife expectancy at the present time, after suffering from traumatic brain injury, the same as it was prior to his injury?
25. Why isn't it?
26. How do you define occupational disability?
27. How is it that Mr. Smith meets this definition?
28. Do you have an opinion regarding James Smith's work life expectancy if he were not occupationally disabled?
29. What is it?
30. How did you arrive at that figure?
31. Do you have an opinion about Mr. Smith's present worklife expectancy?
32. What is that opinion?
33. How did you arrive at that figure?
34. Have you prepared a chart that will help the jury understand how you arrived at this worklife expectancy figure?
35. Please step down and explain your chart to the jury.
36. Dr. Gamboa, based on James Smith's pre- and post-injury earning capacity and pre- and post-injury worklife expectancy, do you have an opinion regarding his lost earnings as a result of the traumatic brain injury he sustained?
37. What is that opinion?
38. Is the loss of earnings stated in terms of present value?
39. How did you arrive at that present value figure?
