Sacramento Man Involved In Two-Car Collision, Part 2 of 3

The following blog entry is written to illustrate a common motion filed during the pre-trial stage of civil litigation. Reviewing this kind of briefing 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 car accident case and its proceedings.)


This case involves an automobile accident that occurred on August 9, 2008, on northbound Watt Avenue south of Marconi in the city of Sacramento, county of Sacramento, state of California. Plaintiff Randall Brown claims that defendant Brenda White was negligent in the operation of her motor vehicle that day. Plaintiff claims physical injury as a result. Defendant disputes liability as well as the nature and extent of plaintiff’s overall claims.

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

Plaintiff Brown did not seek medical attention on the date of the accident, and continued to Lake Tahoe on the date of the accident. Two days later he was seen at Memorial Hospital upon his return trip home from Lake Tahoe and was diagnosed with a closed head injury, cervical sprain, rotator cuff sprain, and a lumbar sprain. Plaintiff was discharged with instructions to follow up with his primary care provider.

After the accident, plaintiff stopped working at Blockbuster, and lost his health insurance benefits. He then sought and received benefits through CMSP, which provides health insurance for low-income indigent adults in thirty four rural counties in California. This program is facilitated by Aetna Blue Cross. Brown continued to treat with a number of different facilities, and the records attached as Exhibit A show the various medical providers he has sought.

As plaintiff has sought medical attention for a lengthy period of time from a number of different providers, the defense has not been able to determine exactly what providers plaintiff is claiming injuries. Upon determination of exactly which medical providers plaintiff seeks to enter into evidence of medical special damages, the defense will be able to then confirm the reasonable amount of that medical billing from Exhibit A. (See Part 3 of 3.)

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

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