Michael D. Donovan

I write to thank you for your assistance with the trial preparation in the [Wal-Mart] class actions and to recommend your service to all those that may consider retaining you. The analysis, mock jury study, theme development, and related services were right on target and contributed materially to the very significant [$187 million] verdict we obtained in the case against Walmart.

The input we received before, during, and after the mock jury study was very helpful in the actual voir dire and jury selection. In addition, your theme suggestions were consistent with our inclinations and proved useful along with the very visual analogies that we in fact adopted at trial. The Walmart smiley face pick-pocket slide was inspired by our work with you and appeared to resonate with the jury.

Please consider me as a very strong reference for all your potential engagements.