Several types of photographs should be taken and gathered.
- Pictures taken before the accident, showing how the victim looked before being injured.
- Pictures taken right after the attack will graphically show the severity of the injuries and implicitly suggest the pain and suffering of the victim.
- Photos taken at the hospital will show the severity of the injuries and will demonstrate what was done during the surgery.
- Photos taken by the plastic surgeon will show the same.
- Photos made during the recovery -- the day the victim gets home, the next day, one week later, and more -- will help to describe how painful, disabling, embarrassing and difficult the healing process was.
- Photos taken at the time of the demand for settlement. The insurance company will rely on those photographs to accurately evaluate the claim.
- Photos taken prior to trial, so they can be admitted into evidence and the jury can take them into the jury room.
