(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Since the attack, Ms. Rich tried to return to work approximately one week post-incident and has tried to work intermittently since the incident, but has been unable to return to her…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 2. Olivia Stark further testified about all the incidents caused by defendant JONES: “Q. After Bobbi slammed on the brakes the first time, did you overhear any kind of complaints about…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) At the time Ms. Rich was examined by Dr. Shortley, it was Dr. Shortley’s opinion that surgery was “almost a medical certainty.” However, since that appointment Ms. Rich was examined by…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) On October 19, 2006, Tim Stark and Olivia Stark were deposed. Their condensed depositions are referenced herein. Mr. and Mrs. Stark were passengers on the bus trip. Mr. Stark is a…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Comparing the two lumbar MRI reports we see the difference. Following the attack by the dog Franz in 2006 the MRI records: “A small amount of extruded disc material into the…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) V. ECONOMIC DAMAGES Past Medical: Meridian Resource Company $ 386,407.13 Trauma Medical Group of Roseville $ 7,017.96 Patient Copays: Sutter Auburn Home Health $ 137.88 Sutter Auburn Faith Hospital $ 167.55…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Post-operatively, Ms. Rich has not done well. She has continued to have left foot drop, right and left foot pain, weakness, and numbness. She has taken numerous medications to control her…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) III. INJURIES After the incident, plaintiff had immediate onset of right side pain. The morning after her return from the trip, she saw Gary Bell, D.C. for her right side pain.…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) In addition, on the same day that Ms. Rich was attacked by Franz, the dog was found to be loose and the dog charged animal control as well. The Animal Control…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Plaintiff, NANCY KLEIN, hereby submits the following Mediation Brief. I. BACKGROUND At the time of the incident, plaintiff, NANCY KLEIN, was 60 years of age. She lived with her husband of…