Frank D’Oro recently obtained a dismissal for waiver of costs during voir dire on a slip and fall case for the defendant. Plaintiff suffered a fall in the defendant’s store and alleged medical expenses of more than $200,000 related to two surgeries and a head injury. Plaintiff rejected a Statutory Offer of $100,000 early in litigation. As trial approached, Plaintiff made a number of demands, ultimately demanding less than the expired Statutory Offer. The defense team settled on a waiver of costs during voir dire after a successful day of arguing crucial motions in limine excluding a theory of liability based on choice of flooring and excluding evidence of the amount of the medical bills.