Jeremy Chevres, of the Ft. Myers office, obtained summary judgment in a case involving the death of a 21-year-old husband and father of a 6-day-old infant. The deceased was crushed while working under a bulldozer where the supports failed. Jeremy was able to keep the focus of the Court on the case law and legal burden in the face of inflammatory evidence. Prior to the hearing, Jeremy laid the groundwork for his win by defeating an attempt to amend the complaint for punitive damages and securing an order denying the amendment with prejudice. As the Court noted, negligence and even gross negligence was ample and proven but did not rise to the conduct required under the statute for employer liability under the virtual certainty standard.