Sample Plaintiff 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
PLAINTIFF’S SETTLEMENT WEEK
PRE-CONFERENCE STATEMENT
Submitted this day of November, 2002
Pursuant to Amended Settlement Week Standing Order 1.2, Counsel for Plaintiff submits this pre-conference statement, subject to Evidence Rule 408.
1. Essential facts. Plaintiff Roger Daltry, a semi-retired rock star, was driving northbound on Cleveland Avenue, south of Polaris Parkway, in suburban Franklin County on June 23, 2001 when his car was struck from the rear by a vehicle driven by Defendant Emily Jackson. Property damage to both cars was significant. Plaintiff was transported from the scene by emergency squad to St. Ann’s Hospital where he was x-rayed, examined, treated, and released. He has had follow up care with Dr. Dolittle. His primary injuries are to his neck and back. Plaintiff still suffers back and neck pain on exertion, which limits his ability to earn a living in the “Legends of Rock Tour” as the lead singer for The Who.
2. Current specials. Plaintiff claims these items of special damages as of this date.
Emergency room care $ 789.75
Dr. Dolittle $ 2,400.00
Physical therapy $ 4,098.00
Voice coach $ 1,400.00
Lost wages $15,000.00
Total $23,687.75

3. Current settlement demand. Based on all the evidence, Plaintiff’s current demand is $80,000.00. Plaintiff is willing to negotiate in Settlement Week.
Respectfully submitted,

O. Watt Ever, Esq.
Counsel for Plaintiff

Pursuant to the Standing Order, this pre-conference statement has been faxed to opposing counsel, but not filed with the Clerk. Counsel for Plaintiff will provide a copy to the volunteer mediator at the Settlement Week conference.


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