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$________ Motor Vehicle Negligence – Rear End Collision – Plaintiff contends collision causes bilateral meniscus tears – Arthroscopic surgery to both knees – Knee replacement on one side – Rotator cuff tear necessitating open surgery – Lumbar herniation – PTSD – Allegedly now unemployable – $________/________ high/low agreement – Damages only.

Suffolk County, NY

The plaintiff’s motion for summary judgment on liability was granted in November, ________ in this rear end collision case. The plaintiff, in his 50s, contended that he sustained bilateral knee tears and underwent bilateral arthroscopic surgery. The plaintiff maintained that despite this intervention, traumatic arthritis necessitated a total knee replacement.

The plaintiff further contended that he suffered a right-sided torn rotator cuff. The plaintiff maintained that it was necessary to convert to an open procedure during arthroscopic shoulder surgery and that he will suffer extensive pain and limitations. The plaintiff also contended that he sustained a lumbar herniation that has necessitated numerous trigger point injections and which will permanently cause symptoms.

The plaintiff further contended that he suffered PTSD that will permanently cause anxiety and depression, nightmares and flashbacks of the event. The plaintiff was employed as an account executive in a job that required him to solicit business from insurance companies arranging for independent medical evaluations. The plaintiff contended that he is permanently unemployable and would have introduced evidence of $________ in lost earnings. The plaintiff further claimed that he will incur approximately $________ in future medical bills.

The defendant denied that the plaintiff’s claims that the accident was the cause of any complaints should be accepted. The defendant maintained that the cross-examination of the plaintiff reflected that although the plaintiff denied on direct that he sustained similar alleged injuries in a prior collision, the evidence reflected that such claims were, in fact, made following an accident that occurred 11 years earlier. The defendant also pointed out that within the first month of the accident, the plaintiff he drove as a salesman thousands of miles. The defendant would have further argued that the jury should consider that the plaintiff, who contended that he was fired several months after the accident because he could not perform his duties, was intimately familiar with personal injury claims and that this factor should further undermine his credibility.The case settled after the plaintiff’s cross-examination for $________.

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  4. Research trial strategies, tactics and arguments.
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