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$________ Motor Vehicle Negligence - Rear end collision - Chain reaction freeway accident - Low impact - Severe injury alleged


This action arose out of a chain reaction freeway accident during which the plaintiff’s vehicle was rear-ended by the defendant’s vehicle. The plaintiff alleged negligence against the defendant driver for failing to maintain a safe traveling distance. The 46 year old male plaintiff claimed that he sustained serious injury to his back including disc bulges in the cervical and lumbar areas of the spine.

The subject accident occurred on August 30, ________ on the Harbor Freeway near the Santa Monica Freeway. The plaintiff, driving a ________ Chevrolet, was rear-ended by the defendant, driving a ________ Chevrolet station wagon while in the course and scope of his employment with Daiichi Jitsugyo of America. The plaintiff’s accident reconstruction expert testified that the initial impact was between the defendant’s station wagon and the plaintiff’s vehicle at between 11 to 16 miles per hour and then the station wagon was struck by a ________ Jeep CJ following behind it. The medical evidence indicated that the plaintiff had a pre-existing narrowing of his spinal cord canal in the neck, and a pre- existing pars interarticularis in the low back at L5, S1. The plaintiff claimed that as a result of the accident, he sustained disc bulges of two to three cms. at C5-6 and C6-7. Four months post-accident, the plaintiff underwent surgery to the cervical area with cadaver bone plugs inserted at C5-6 and C6-7. One and one-half years post-accident, the plaintiff underwent surgery to the lumbar spine involving the removal of 6mm disc L4-5 with selby fixation device with screws in vertebral bodies installed.

According to the plaintiff’s medical experts, the plaintiff will probably have to undergo removal of screws and/or whole device in low back as it irritates plaintiff’s lumbar area. As of November 19, ________, further MRI’s of plaintiff’s neck revealed disc bulging at C2-3, C3-4 and C4-5 with future surgery likely, according to the plaintiff’s experts. The plaintiff’s medical specials to date in the amount of $________ were all paid by Workers’ Compensation.

The plaintiff claimed lost earnings to date in the amount of $________. The plaintiff claimed he would be unable to return to his previous employment as a location manager in the television industry which paid $________ annually, and would be limited to sedentary work. Due to his age and injuries, it would be unlikely that the plaintiff could earn more than $________ to $________ per year, according to the plaintiff’s vocational expert. The plaintiff’s economist testified that the plaintiff’s present value, future loss of earnings amounted to $________ assuming the plaintiff would have retired at age 65.

The defendant claimed he was initially rear-ended by the ________ Jeep CJ operated by a third driver. The third driver settled out for $________ policy limits. The defendants’ engineering expert testified that damage to the vehicles was minimal and could hardly be observed in photographs. The defense expert maintained that because the collision was very low speed, the vehicles bounced off each other like billiard balls. The Jeep hit the station wagon at 3.8 miles per hour, which accelerated the station wagon to 3.2 miles per hour which, in turn, accelerated the plaintiff’s vehicle to 3 miles per hour, according to the defense expert. The defendants’ medical expert testified that the plaintiff’s disc could not have herniated in such a low speed collision. The expert stated that the plaintiff would have to have tearing of the ligaments between the spinus processes to have a herniated disc. Because the plaintiff did not see a doctor for three weeks and continued to work for two months, he could not have had a herniated nucleus pulosis as claimed, according to the defense medical experts. The jury found for the plaintiff and returned a verdict of $________.

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