In a case arising out of a slip and fall accident in a retail establishment or supermarket, the personal injury attorney for the plaintiff (the person who was injured in the slip and fall accident and filed the lawsuit) should cover the following topics with the jury:

Store operating records

  1. Sweep records or logs
  2. Employee time cards/li>
  3. Accident or incident reports/li>

Store operations

  1. Store operations manual
  2. Employee manuals or handbooks
  3. Store or corporate safety manual
  4. Store maintenance manual
  5. Store bulletins or advisories regarding safety issues
  6. Transcripts of employees’ computer assisted training programs

Industry standards

Government codes and ordinances


When a slip and fall lawsuit is filed, the parties to the lawsuit, through their personal injury attorneys, engage in a process called “discovery,” through which each party learns what the other party knows, or claims to know, about the slip and fall incident that is the subject of the lawsuit. The process of discovery includes “interrogatories” (written questions), written requests to produce documents, written requests for admissions (requests to admit the truth of certain facts), and depositions (an oral question and answer session, recorded by a court reporter). At trial, much of this information will be presented to the jury, either through direct examination of witnesses or cross-examination. Discovery materials that may be useful include:

  1. Deposition testimony of store director or manager
  2. Deposition testimony of store safety director
  3. Deposition testimony of employee or associate responsible for cleaning or inspection
  4. Deposition testimony of each employee-witness
  5. Interrogatories or requests of admission regarding maintenance or inspections
  6. Deposition testimony of designated expert for the defense

Trial aids or exhibits

An experienced personal injury attorney will bring visual aids to the trial to keep the jurors engaged in the testimony and help them follow along. Visual aids that might be helpful in the trial of a slip and fall injury case, include:

  1. Color photographs to illustrate both expert and lay (non-expert) witness testimony
  2. Plans or diagrams of the slip and fall accident site
  3. Enlarged copies of expert’s field data sheets, drawings or diagrams
  4. Models or video recordings that illustrate operations or conditions
  5. Exemplar bottles or containers of spilled liquid or debris
  6. Summary boards containing either points of law or expert opinions, or both