Bank Executive Suffers Traumatic Brain Injury In Sacramento Car Accident, Part 4 of 4

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 brain injury lawsuit and its proceedings.)


Plaintiff had pre-existing degenerative disc disease (DDD) in her neck and back and occasional left shoulder pain. In the accident, she aggravated these conditions causing her DDD to lit-up. Mrs. White has continued to have left side weakness and low back flare ups. These problems have been treated with chiropractic therapy, physical therapy and massage therapy to manage her neck, shoulder and back symptomatology. Defendants concede she suffered soft tissue injuries in the accident but claim they should have healed in a matter of a few months.

Total Medical Bills without Prescriptions. $ 31,020.45

In November 2007, Mrs. White was hired by the County Bank. As a Vice-president at County Bank, Mrs. White’s salary was set at $87,500.00 plus benefits and bonuses. After the accident, she was let go within weeks for strategic reasons by County Bank. Mrs. White tried to get another job with a bank but was unsuccessful. In April 2008, Mrs. White took a job as a front desk receptionist/office assistant at Lee Chiropractic Clinic where she was paid $11.00 per hour. Mrs. White was hired for her lovely demeanor and obvious people skills and was expected to learn the job within a few months. Unfortunately, Mrs. White’s cognitive injury led to her having difficulty working as a receptionist. Dr. Lee explained that Mrs. White had numerous difficulties with her job requiring frequent retraining as follows:

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

When we initially trained Jackie, she was in severe pain and on heavy medications. Since then we have completely retrained her from scratch three more times and on some specific tasks over 20 times and still counting. She grasps a concept for a short while and then either transforms it into something incorrect or completely forgets to perform the duty. She confuses and scatters very easily especially when tired or in pain to this Black. Any lay person would surmise that her brain is not functioning properly.

Due to the number of mistakes and system breakdowns in Jackie’s work, we have tried adding various job aids such as appropriately placed tasks lists to help her sustain a routine pattern. These have met with marginal success since often she needs to be reminded that the job aid even exists. To help her feel successful we have also tried to lighten her load by reducing the scope of her job duties where we could.

Even though Jackie is so well-intended and shows great effort, it is difficult to trust that her work is ever complete or correct.Dr. Lee’s letter clearly indicates that Mrs. White has significant cognitive problems in the wake of the accident.

Mrs. White’s employment loss was analyzed by economist Alan Stein. After subtracting the wages Mrs. White received since the accident, Stein concluded that Mrs. White’s employment loss, discounted to present value, amounted to $439,120.00, assuming she only worked to age 65.

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

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