All The Way To Verdict | Amy Collignon Gunn , Erica B. Slater That's your argument for $18m dollars?

Status Update: September 14, 2026

Primary-source evidence recovered from the circuit-court docket now shows exactly how the $48.1 million “record-breaking” jury verdict in Anyan v. Mercy Hospital / Dr. Daniel McNeive was contractually limited to $18 million nine minutes before the jury spoke.

The Smoking-Gun Text Message (4:47 p.m., March 25, 2025)

While the jury was still deliberating, plaintiff’s counsel Erica B. Slater (Gunn | Slater Law Firm) and defense counsel Mandy J. Kamykowski jointly drafted a four-line agreement in an iPhone Notes app. Slater then texted it to Kamykowski’s cell phone. The exact terms, later filed under oath in Plaintiff’s Memorandum in Support of Motion to Enforce Settlement (May 15, 2025), read:

8 and 18
All the way to verdict
Confidentiality to high/low
No non disparagement

That is the entire written memorial of the high-low agreement that capped gross recovery at $18 million.

Minute-by-Minute Timeline (March 25, 2025)

12:42 p.m. — Jury begins deliberations.
~3:00–4:40 p.m. — High-low negotiations: defense $12 M lump-sum rejected; plaintiff $10 M/$20 M; defense $8 M/$15 M; final defense offer $8 M/$18 M accepted.
4:47 p.m. — Four-line text agreement sent and confirmed via read receipts.
4:56 p.m. — Jury returns Phase 1 verdict: $28.1 million compensatory + liability for punitive damages.
4:56–5:59 p.m. — Jury deliberates Phase 2 (punitive amount). Defense makes no request to stop deliberations or clarify that punitive damages were excluded.
5:59 p.m. — Jury returns $20 million punitive award (total $48.1 million).
Post-verdict sidebar — Plaintiff announces the $18 million settlement. Defense for the first time claims the high-low applied only to net compensatory damages after statutory caps.
6:15–6:38 p.m. — On the record, defense counsel admits to the court: “There was no discussion of caps, Your Honor.”
7:39 p.m. — Defense attorney Phil Willman calls plaintiff’s counsel asking to “hold on everything” so defendants can “confirm the settlement at $18 [million]” the next day.

Why “All the Way to Verdict” Matters

The phrase is now the central disputed term on appeal. Plaintiff’s counsel (Gunn | Slater / Simon Law Firm) is moving to enforce the $18 million ceiling as a full and final settlement of the entire claim. Defense contends the agreement somehow excluded punitive damages and was subject to Missouri’s medical-malpractice statutory caps.

The enforceability of this four-line text exchange will determine whether the Anyan family ever sees more than $18 million—or whether the $48.1 million figure returns to the table only to be reduced by remittitur and statutory ceilings.

Appellate Status (as of September 11, 2026)

Multiple appeals have been consolidated into Case No. ED113824 (Missouri Court of Appeals, Eastern District). Related dockets: ED113933, ED114055, ED114232. The high-low agreement, the meaning of “all the way to verdict,” and the continued public advertising of the uncapped $48.1 million verdict remain live issues.

The 62 % Omission Continues

From the moment the jury left the courtroom, Gunn | Slater and The Simon Law Firm issued press releases and social-media posts celebrating a $48.1 million “historic” medical-malpractice verdict. Regional outlets (KSDK, KMOV, Missouri Lawyers Media) repeated the figure. None disclosed the pre-verdict high-low that had already surrendered $30.1 million—more than 62 % of the advertised amount. That omission remains uncorrected on firm websites and prior promotional materials to this day.

Statutory Reality Check (If the High-Low Collapses)

Even if the $48.1 million verdict is reinstated, Missouri law imposes strict limits:

Noneconomic damages are capped (RSMo § 538.210) with annual inflation adjustments and a higher tier only for catastrophic injury.

Punitive damages against health-care providers require clear-and-convincing proof of intentional or malicious misconduct; mere negligence or conscious disregard is insufficient (RSMo § 538.210.8).

NOTE: Plaintiff counsel presented to the jury a lengthy polemic with regard to how outrageous the professional misconduct was of Dr. Daniel McNeive. That the imposition if punitive damages was for the purpose of warning other health care provides not to engage in the same conduct and further, to protect future patients from Dr. Daniel McNeive. 

Herein lies the hypocrisy that the argument for punitive damages presented by plaintiff counsel is entirely disingenuous and is for the sole purpose of more money for the law firm and the plaintiff client. 

A check on the status of Dr. Daniel McNeive with the Missouri State Board Of Registration For The Healing Arts reveals that no one, not the Anyan family, not The Simon Law Firm P.C., not Gunn Slater had taken the time to file a report with the board. 

The Missouri State Board Of Registration For The Healing Arts is the appropriate mechanism to employ when a doctor, physician is purported to be a genuine threat to clients and patients. Plaintiff counsel spent months preparing their argument for the jury that Dr. McNeive was a bad physician that deserved the imposition of punitive damages. However, that did not dedicate just two hours for a staff paralegal to file a report with the Missouri Board. - You may rightly infer the motive or lack thereof.

Courts must enter remittitur when awards exceed the statutory ceilings.

Thus the “lottery-ticket” number that was marketed to the public was never the realistic recovery figure under either the high-low agreement or the statutory framework.

Demands (Updated)

Immediate public disclaimer on every webpage, press release, award submission, and social-media post that references the Anyan verdict, stating that a high-low agreement limited enforceable recovery to $18 million before the jury returned.

Transparent accounting of all sums actually recovered by the Anyan family.

Formal referral to the Missouri Office of Chief Disciplinary Counsel for review under Rules 4-7.1 (misleading communications) and 4-3.6 (trial publicity).

Full production of the complete text-message thread and any contemporaneous notes surrounding the 4:47 p.m. agreement.

Demand an explanation from The Simon Law Firm P.C. , Gunn Slater Law Firm why they did not proceed to file a report and complaint with the Missouri State Board Of Registration For The Healing Arts naming Dr. Daniel McNeive for investigation if, Dr. McNeives conduct was as egregious and grievous as they presented to a jury for the purpose of the imposition of a punitive damages award.

Primary Sources Now Public

Plaintiff’s Memorandum in Support of Motion to Enforce Settlement (May 15, 2025) containing the exact four-line text. The Memorandum has been recovered from CaseNet Mo. and is now archived on the Jury-Watch.Org website: https://jury-watch.org/gunn-slater-law-firm

Trial-court docket: 21SL-CC03944 (St. Louis County).
Consolidated appeal: ED113824 and companion dockets.
Supporting analysis and archived transcripts hosted at jury-watch.org and Academia.edu.
The $48.1 million figure was never available for recovery. The public was told otherwise. The four-line text message—“8 and 18 / All the way to verdict”—is the document that proves it.

Sign and share so Missouri consumers, injured families, and the disciplinary authorities can see the full record.

— Update prepared from the primary-source memorandum and docket materials recovered and published by Albert B. Pepper Jr. / Phoenix Rising Productions LLC, September 2026.