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    Past Medical Expenses

    Uploaded by

    Logan Dupré

    Copyright:

    © All Rights Reserved
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    Past Medical Expenses

    Uploaded by

    Logan Dupré
    12 views2 pages

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    © © All Rights Reserved

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    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    12 views2 pages

    Past Medical Expenses

    Uploaded by

    Logan Dupré

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    You are on page 1of 2

    Past Medical Expenses $455,981.

    14
    Past Wage Loss $26,420.75
    Future Wage Loss $80,000.00
    Vocational Rehabilitation $8,000
    Past Loss of Household Services $45,080.00
    Future Loss of Household Services $124,073.00

    General Damages $731,401


    TOTAL EXPOSURE 1,462,802.00

    Items for mediation to make sure you throw in to get number up

    1. Past Medical expenses

    2. Future Med exp including surgeons

    a. fee Hospital costs

    b. Anesthesiologists fee

    c. Hardware such as plates or screws ( very expensive)

    d. Physicians assistant

    e. Monitoring system post surgery ( usually around 4-5,000)

    f. for future PT -post surgery

    3. General damages

    a. Loss of enjoyment of life

    b. Mental and physical pain and suffering

    c. Permanent scarring

    d. And short term or long term disability If applicable

    e. lost wages ,

    f. past and future ( consider how long she will be out of work for future surgeries)
    g. Will she have any permanent limitations or restrictions post surgery? If so that’s

    an item of damage also.

    h. Your dr could answer these questions Like she may never be able to lift more

    than 20 pounds as an example

    i. Be sure to like on as much as you can to bump up the figure As a rule of thumb, I

    ask for at least $100,000 in general damages ( the minimum) PER major surgery-

    like back, neck or hip

    j. Less if it’s a knee or ankle etc

    k. If she fractured anything that’s a lot in general damages too So do not leave that

    mediation without at least 300k in gen damages for 2-3 surgeries plus special

    damages as per above for lost income and med exp

    l. Even though she has no loss of consortium you can argue that less sex withher bf

    due to injuries is compensable under loss of enjoyment of life ( doesn’t hurt to

    throw all this in)

    m. Also consider lesser items

    n. Money she paid out for maid to do housework,

    o. yard man,

    p. nanny etc AND if you want to pinch pennies Mileage of 50 cents per mile to drive

    to Pt dr appts etc or if she has to pay someone to take her or use uber

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