V. ECONOMIC DAMAGES
Past Economic Damages:
Meridian Resource Company $ 21,454.67
Valley MRI & Family Imaging Center $ 1,306.80
Central Anesthesia Medical Group, Inc. $ 100.32
Northern California Cardiology Associates Med. Grp. $ 32.00
Mark Hambly, M.D. $ 658.26
Jeff Jones, M.D. $ 2,693.00
Randall Armstrong, MD $ 220.00
Roseville Memorial Hospital $ 1,079.27
EMPI $ 73.75
HealthCare Clinical Laboratories $ 406.00
Sutter General Hospital (deductible) $ 1,508.13
Ramnick Clair, M.D. (estimate) $ 1,200.00
Roseville Delta Emergency Physicians $ 354.92
St. Joseph’s Medical Center $ 6,461.25
Smallie Chiropractic $ 944.35
Roseville Physical Therapy $ 1,186.00
Richard Harty, P.T. $ 270.00
Prescriptions $ 1,595.57
Total Past Medical $ 41,544.29
Past Wage Loss $ 67,465.56
Future Wage Loss $ 674,655.60
Total Wage Loss $ 742,121.16
Richard Harty, P.T. $ 360.00
Roseville Physical Therapy $ 1,200.00
Surgery $ 125,000.00
Medication $ 41,760.00
Physical Therapy $ 50,112.00
Total Future Medical $ 218,432.00
TOTAL ECONOMIC DAMAGES $ 1,002,097.45
Copies of her bills are referenced herein.
Please note, Ms. Rich’s wage loss and medical damages are increasing weekly.
VI. PUNITIVE DAMAGES
As discussed above, defendant, Paul Stevens, had already signed a document acknowledging the subject dog Franz was a vicious dog that had to be restrained. Despite this and with a conscious disregard for the safety of others, Paul Stevens permitted the dog to run free and attack Ms. Stevens.
We have sued Mr. Stevens for punitive damages. As you know, punitive damages, if awarded, must be paid personally by Mr. Stevens. It will not be paid by his insurance.
A failure by Allstate Insurance Company to settle this case will expose Mr. Stevens to financial ruin.
VII. SETTLEMENT OFFER
Plaintiff, Kerri Rich, still suffers with daily low back pain, numbness, left leg pain, and difficulty sleeping. She is unable to work the jobs and hours she enjoyed before being attacked by defendant’s dog. She is still receiving significant medical treatment for her injuries stemming from the dog attack. Plaintiff will accept payment of defendant’s policy limits in settlement of this case. In exchange she will provide defendant with a full release and extinguish all applicable liens.
This offer of settlement will terminate and expire at the close of the Mediation on March 3, 2007. After that point we will consider this a no limits policy.
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.