The following blog entry is written to illustrate a common motion filed during civil litigation. Reviewing this kind of filing should help potential plaintiffs and clients better understand how parties in personal injury cases present such issues to the court.
(Please also note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this automobile accident lawsuit and its proceedings.)
Ms. Johnson returned for a follow-up examination with Dr. Greene on March 17, 2009. She reported little improvement in her low back pain and continued to experience weakness and pain radiating into the right lower extremity. Dr. Greene recommended a lumbar discography from L1-2 through L5-S1 based on his review of her lumbar spine MRI and symptomatology. He further noted Ms. Johnson would be a candidate for surgical discectomy depending on the results of her lumbar discography.
On June 16, 2009, Ms. Johnson underwent lumbar discography which proved positive for 112 10/10 severe pain at L4-5 and positive for 8/10 concordant pain at L2-3. Ms. Johnson was then admitted for right percutaneous discectomy with automated nucleotome and pitutitary rongeur under fluoroscopic monitoring at L4-5.
As a direct and proximate result of the injuries that Ms. Johnson suffered due to defendant Black’s negligence, she incurred the following medical expenses:
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.
1. Donald Hall, D.C. (Exhibits 4 and 5 ) $ 934.11
2. Michael White, D.C. (Exhibits 6 and 7 ) $10,010.00
3. Robert Lee, M.D. (Exhibits 8 and 9 ) $ 600.00
4. Spinal Imaging, Inc. (Exhibits 10 and 11 ) $ 300.00
5. Valley Imaging (Exhibits 12 and 13 ) $ 2,362.00
6. Edward Long, M.D. (Exhibits 14 and 15 ) $11,200.00
7. Valley Spine Surgery Center (Exhibits 16 and 17 ) $56,142.83
8. Roy Greene, M.D. (Exhibits 18 and 19 ) $10,000.00
9. University Medical Center (Exhibits 20 and 21 ) $ 3,888.88
10. CA Emergency Physicians (Exhibit 22 ) $ 330.00
11. Pharmacy Receipts (Exhibit 23 ) $ 179.26
Past Medical Expenses: $95,947.08
Unfortunately, Ms. Johnson continues to experience ongoing pain and limitation with daily activities and difficulty sleeping secondary to persistent axial low back pain.
SETTLEMENT NEGOTIATIONS
No meaningful settlement negotiations have been made to date.
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.