(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.)
X. SPECIAL DAMAGES
Plaintiff was rushed by ambulance to Mercy San Juan Hospital. After 14 days she was transferred to U.C.Davis Medical Center where she was hospitalized for 22 additional days. The bills for the foregoing are as follows.
Sacramento Metropolitan Fire District $ 1,021.97
UC Davis Med Center $ 150,450.62
Mercy San Juan Hospital $ 210,437.00
TOTAL DAMAGES $ 361,909.59
At time of trial plaintiff will be entitled to present to the jury the sum of $361,909.59, itemized above. Plaintiff’s medical bills are referenced below. Plaintiff has also been served with a lien from Catholic Healthcare West for Mercy San Juan Hospital in the sum of $210,437.00. There remains no Medi-Cal lien for these charges as it has been withdrawn. Catholic Healthcare West has refunded all monies received from Medi-Cal and the Medi-Cal lien is cancelled because the defendant tortfeasors are insured and Medi-Cal is, by statute, the payer of last resort.
XI. SETTLEMENT OFFERS
Plaintiff has sued Chris Brown for compensatory and punitive damages as a result of his drunk driving. Plaintiff is also entitled to an award of attorney fees if defendant is convicted of a felony. In addition, plaintiff has sued Paul and Mary Brown for negligent entrustment of the vehicle to their son.
The defendants are insured by Allstate Insurance with policy limits of $500,000 per accident plus an umbrella in the sum of $1,000,000. Total insurance coverage available for all three claims arising from the collision is, therefore, $1,500,000.
A. Offer Under C.C.P. 998
On February 29, 2007, this plaintiff served on defendants an offer of settlement under CCP section 998 in the total sum of $1,190,000.00. That offer has expired. (See Part 10 of 10.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.