This deposition is from our March 2024 wrongful death trial in Atlanta, Georgia. Our client, "Kisha," was in bed asleep inside an apartment. Outside the apartment there was a shooting, and a stray bullet flew into the apartment and hit and killed Kisha. The shooting had nothing to do with Kisha or the people inside the apartment.

We filed a lawsuit on behalf of Kisha's family against the apartment complex--this is referred to as a negligent security case. We had to prove (1) there was dangerous activity in the past that would have made it foreseeable to the apartment complex that Kisha's shooting would happen (essentially, there was so much crime in the past, it was likely to happen again) and (2) the apartment complex could have prevented Kisha's death if it would have taken reasonable steps to prevent and deter crime, given what it knew about in the past.

This deposition is of the Vice President of the apartment complex's parent company. Under questioning, the VP admits that apartment complex knew about a laundry list of very dangerous prior incidents before the shooting that killed Kisha.


You can also find the trial testimony of the Owner and Regional Manager on our channel.

This deposition was played for the jury as evidence at trial. The jury awarded a total verdict of $3.8 million.