Plaintiff construction worker, who was in his 50s, was loading gasoline and diesel fuels into his work vehicle at defendant’s terminal fuel dispensing bay. After he attached a cable to the load rack electronic terminal apparatus, he stepped over the cable and suddenly slipped and fell on the terminal’s pavement floor. His alleged bodily injuries include damage to his head, neck, left shoulder, left rib cage, left knee, and low back, as well as psychological stress. His knee and back injuries required surgery. He previously had reconstructive surgery on his shoulder due to an earlier work injury. Plaintiff retained a number of experts, including a life care planning expert and economist to accurately assess prior and future medical costs.
Question(s) For Expert Witness
- 1. To what extent do plaintiff’s asserted disabilities impede his ability to live independently?
- 2. What are the costs associated with his limitations?
Expert Witness Response
Plaintiff can independently wash, dress, and bathe himself. He watches television, uses a computer and performs light shopping and light household chores along with his wife. He has difficulty performing heavier household chores due to his low back pain and functional limitations. He requires a homemaker two hours a day, seven days a week. The cost of a private homemaker in the area ranges from $16.30 – $22 per hour.
Careful consideration has been given to the in-person life care planning evaluation, as well as the medical evaluations and records contained in the file. We are dealing with an individual who has disabling medical conditions resulting in physical impairments. It is anticipated that these disabilities will continue throughout plaintiff’s life expectancy and affect his ability to function independently. The assessment of plaintiff’s current and future medical care and rehabilitation needs was made based on my interview, review of the records, and knowledge of equipment, technology, and treatments that can assist in his care and development. An attempt has been made to review the reasonable cost of care based upon 2014 local rates without consideration for price increases or inflation. There may be variations and plan modifications made with plaintiff’s treating physicians, family, and rehabilitation coordinator.