Sample Defendant Statement
IN THE COMMON PLEAS COURT OF FRANKLIN COUNTY, OHIO
CIVIL DIVISION
ROGER DALTRY, ]
Plaintiff, ]
] CASE NO. 01CVC-10-9999
]
vs. ] JUDGE WARREN PEACE
]
EMILY JACKSON, ] Defendant. ]
]
SAMPLE
DEFENDANT’S SETTLEMENT WEEK
PRE-CONFERENCE STATEMENT
Submitted this day of November, 2002
Pursuant to Amended Settlement Week Standing Order § 1.2 and in response to Plaintiff’s pre-conference statement, Counsel for Defendant submits this pre-conference statement, subject to Evidence Rule 408.
1. Essential facts. Plaintiff Roger Daltry, an over-the-hill rock star, was driving northbound on Cleveland Avenue, south of Polaris Parkway, in suburban Franklin County on June 23, 2001 when his luxury car was bumped from the rear by a vehicle driven by Defendant Emily Jackson. Defendant Jackson was not speeding at the time, and was merely distracted by the prospect of the upcoming ‘N Sync concert at the Polaris Amphitheater. Property damage to the cars was described by the investigating officer as “moderate”. Plaintiff claims injuries to his neck and back. Plaintiff still claims back and neck pain long after the accident, even though there are no objective findings. Defendant disputes limitations on Plaintiff’s ability to earn a living as the lead singer for The Who.
2. Current defenses. Defendant has dropped the defenses of improper jurisdiction and improper venue, as the collision occurred just south of the Franklin-Delaware County line. Defendant will stipulate liability. Defendant asserts that some of Plaintiff’s injuries were pre-existing, based on his long career as a rock singer, and that his lost wages are overstated. Defendant disputes the need for a voice coach as a result of this accident. Plaintiff’s voice problems are due to overuse, and not this accident.
3. Current settlement offer. Based on all the evidence, Defendant’s current offer is $4,500. Defendant is willing to negotiate in Settlement Week.
Respectfully submitted,
Reece Judicata, Esq.
Counsel for Defendant
Pursuant to the Standing Order, this pre-conference statement has been e-mailed to opposing counsel, but not filed with the Clerk. Counsel for Defendant will provide a copy to the volunteer mediator at the Settlement Week conference.
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