High School Student Suffers Traumatic Brain Injury In Sacramento Automobile Accident, Part 5 of 8

Total economic damages if plaintiff gets full-time employment (present value): $1,105,832.30
Total economic damages if Plaintiff gets part-time employment (present value): $1,633,832.30

As mentioned above, the police report concluded that the cause of the accident was defendant, Ms. Jones.


Nine days after the crash, Ms. Jones’ father drafted a letter opining that there may have been “black-ice” on the pavement which was a cause of the accident. Even though this letter was signed by Ms. Jones, she testified in her deposition that she had no such opinion or recollection.

The depositions of both CHP investigating officers were taken in this case. Both officers testified that there was no “black-ice” on the edge of the pavement. There was some frost. Both officers testified that the presence of the frost was not a factor in the collision.

One of the investigative officers was Kinley Jong. Officer Jong testified as follows in his deposition at page 40:26-41:19:
Q. “Sir, if you were filling out this page two, having observed the accident and investigated it, would you have marked under roadway Surface, A, B, C, or D?

A. I would have marked A.

Q. And A is dry?
A. Yes.

Q. And tell us again your reason that you would have marked A and not something else.

A. Because Officer Pedretti and I discussed this at length at the scene, because we knew that it would probably be brought up. And because of where the tire friction marks started and – and how it flowed through that area, we both agreed that it didn’t have anything to do with the accident.

Q. The frost condition had nothing to do with this accident?

A. Yes.

Q. That was your opinion?

A. Yes.

(See Part 6 of 8.)

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

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