I-75 rear-end. $1,275,000 pre-deposition settlement.

Our client, C.M., a 51-year-old project manager with a Doral logistics firm, was stopped in afternoon traffic on I-75 eastbound, just east of the NW 137th Avenue exit, when a 53-foot dry van trailer pulled by a Volvo tractor struck the rear of his Toyota 4Runner at an estimated 41 mph. The trucker did not brake before impact — telematics later confirmed an unbroken throttle and no brake-application within four seconds preceding the collision. C.M. suffered a C5-C6 disc herniation that ultimately required a two-level anterior cervical discectomy and fusion, plus a torn rotator cuff in his left (non-dominant) shoulder that required arthroscopic repair six months after the fusion healed.

The trucker was an employee of a Florida-based mid-sized motor carrier operating under federal authority. We knew within 90 minutes of the intake call that this would be a federal-discovery case: FMCSA hours-of-service records, Qualcomm telematics, driver-qualification file, drug-and-alcohol testing records, the carrier's Compliance, Safety, Accountability (CSA) score history, and all maintenance records on both the tractor and the trailer. Spoliation letters covering each of those categories went out the next morning, including a specific demand that the carrier preserve the ELD device itself in case the data needed forensic recovery.

Discovery revealed that the driver had logged just over 10 hours of on-duty time in the period preceding the crash — within federal limits, but barely — and had received two prior fatigue-related warnings from the carrier's safety department within the preceding 90 days. The carrier had a $1M primary policy with a $5M layered excess policy on top. The combination of clear liability, federal-statutory violations of 49 CFR 392.3 (fatigue), and stackable coverage created a high-value pre-deposition mediation posture.

Sterling & Reyes prepared a 47-page mediation brief built on the federal violations and the carrier's CSA-score history, supported by a board-certified neurosurgeon expert on permanency and a forensic accountant on lost earnings. After a single eight-hour mediation session held at the carrier's defense counsel's office on Doral Boulevard, the case settled for $1,275,000 — funded approximately 70/30 from the primary and excess policies. C.M. was back at work part-time within six months of the second surgery.