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The Numbers, Studies and Statistics Behind a  Personal Injury/Wrongful Death Economic              Damages Analysis     Pr...
SOURCES OF INFORMATION   Determining Economic Damages, James    Publishing, Gerald Martin, Ph.D.   ValuSource.com is bet...
WHAT IS DISCOUNTING TO PRESENT VALUE?The process of converting future cash flow(s) into a current, present value, lump-su...
WHY DOES PRESENT VALUE MATTER? Economic losses are calculated to the “Present  Value” to quantify a steady stream of lost...
THE REPLACEMENT VALUE OF A LIFEEssential Elements  1.   Loss of Earning Capacity that would have been       earned from jo...
THE REPLACEMENT VALUE OF A LIFEEssential Elements  4.   Medical & Rehabilitation Bills incurred in the       past plus est...
TIMELINE FOR A DAMAGES ANALYSISLoss of Earning Capacity & Loss of Fringe BenefitsLoss of Household Services & Medical Bill...
Essential Elements1. LOSS OF EARNING CAPACITYa)   Establish the earnings base/earning capacity     (what was earned or cou...
Essential Elements1. LOSS OF EARNING CAPACITYc)   Inflation often removed from earnings     increases (and correspondingly...
Essential Elements1. LOSS OF EARNING CAPACITYf)   Deduct the mitigating earnings still able to     earng)   Taxes are not ...
Joan Smith                                                                                        10-30-95                ...
Joan SmithFamily Member Education and Income Summary                                                                      ...
Essential Elements1. LOSS OF EARNING CAPACITYh)   Sources of Income Data:        W-2s, 1040s, paystubs, depos of family  ...
Essential Elements1. LOSS OF EARNING CAPACITYh)   Sources of Income Data (cont’d):        A vocational rehabilitation exp...
Essential Elements1. LOSS OF EARNING CAPACITYi)   Personal Consumption - in WD     cases, generally subtract a % (might ju...
Essential Elements1. LOSS OF EARNING CAPACITYi)   Personal Consumption (cont’d)        Assumptions often made for the num...
Essential Elements2. LOSS OF FRINGE BENEFITSa)   Part of the job or occupationb)   Expressed in the calculation as a % of ...
Essential Elements2. LOSS OF FRINGE BENEFITSc)   Examples:     11.7% Employer paid FICA, Unemployment & Worker’s          ...
Traditional Fringe Benefits-Private IndustryBureau of Labor Statistics Economic News Release, June 7, 2012, "Employer Cost...
Essential Elements2. LOSS OF FRINGE BENEFITSd)   Sources of fringe benefit data:        Interview or depo of employer or ...
Essential Elements2. LOSS OF FRINGE BENEFITSe)   Unvested or unconventional benefits        Lucrative defined benefit pen...
Essential Elements3. LOSS OF HOUSEHOLD SERVICESa)   Services that can no longer be performed due     to injury or deathb) ...
Essential Elements3. LOSS OF HOUSEHOLD SERVICESd)   The loss, even though not directly compen-     sated like regular empl...
Essential Elements3. LOSS OF HOUSEHOLD SERVICESe)   Valuation methods are generally based on     hours spent times an hour...
Essential Elements3. LOSS OF HOUSEHOLD SERVICESg)   Most do not keep a log of hours spent on     household choresh)   Sour...
Table 6. Married males that work full-time, wife does not work, youngest child ages 13 to 17                              ...
Essential Elements4. MEDICAL AND REHABILITATION BILLSa)   Bills already incurredb)   Estimated future bills from a Life Ca...
Essential Elements5. DISCOUNT ALL LOSSES TO PRESENT VALUEa)   Pre-Trial Losses         Calculate losses prior to Trial Da...
Essential Elements5. DISCOUNT ALL LOSSES TO PRESENT VALUEb)   Post-Trial Losses         Calculate losses after Trial Date...
Essential Elements5. DISCOUNT ALL LOSSES TO PRESENT VALUEc)   Discount Rate        Using a “risk-free” rate (U.S. Treasur...
Bring the 5 Essential Elements Together                                       Wrongful Death Economic Damages Report      ...
Lost Earnings, Fringe Benefits, Household Services and Future Medical CostsExhibit A                                      ...
Personal ConsumptionExhibit B                                                      Earnings             Pres.    Net    Pl...
Lost Production of Household ServicesExhibit C                                     Pre-Injury                             ...
Personal Injury & Wrongful Death Economic Damages Analysis
Personal Injury & Wrongful Death Economic Damages Analysis
Personal Injury & Wrongful Death Economic Damages Analysis
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Personal Injury & Wrongful Death Economic Damages Analysis

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Learn about the processes, economic studies, online statistics and well known statistical studies used in a personal injury and wrongful death loss of earning capacity economic damages analysis.

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Personal Injury & Wrongful Death Economic Damages Analysis

  1. 1. The Numbers, Studies and Statistics Behind a Personal Injury/Wrongful Death Economic Damages Analysis Presented by: Robert Vance, CPA, ABV, CFF, CVA, CFP Forensic & Valuation Services, PLC 901-507-9173 www.ForensicVal.com rvance@ForensicVal.com
  2. 2. SOURCES OF INFORMATION Determining Economic Damages, James Publishing, Gerald Martin, Ph.D. ValuSource.com is beta testing Advocate Personal Injury Economist, Employment Law Economist and Wrongful Death Economist National Association for Forensic Economists www.nafe.net which publishes the Journal of Forensic Economics A number of studies and websites will be referenced throughout
  3. 3. WHAT IS DISCOUNTING TO PRESENT VALUE?The process of converting future cash flow(s) into a current, present value, lump-sum figureCash flows are discounted to account for the “Time Value of Money” End of Year 0 +1 +2 +3 +4 3% $1,000 $1,000 $1,000 $970.87 $942.60 $915.14 $2,828.61 = PVA3
  4. 4. WHY DOES PRESENT VALUE MATTER? Economic losses are calculated to the “Present Value” to quantify a steady stream of lost past and lost future income into a single, lump-sum figure for settlement or award purposes The Present Value of the economic losses is “The Replacement Value of a Life”
  5. 5. THE REPLACEMENT VALUE OF A LIFEEssential Elements 1. Loss of Earning Capacity that would have been earned from jobs or occupations, less mitigating earnings, if any 2. Loss of Fringe Benefits that are part of the jobs or occupational income streams 3. Loss of Household Services that would have been performed, less services still able to perform
  6. 6. THE REPLACEMENT VALUE OF A LIFEEssential Elements 4. Medical & Rehabilitation Bills incurred in the past plus estimates of future bills from a Life Care Plan 5. Discount all Losses to Present Value, usually to the Trial Date
  7. 7. TIMELINE FOR A DAMAGES ANALYSISLoss of Earning Capacity & Loss of Fringe BenefitsLoss of Household Services & Medical Bills Injury Trial Worklife Life Date Date Expectancy Expectancy Past or Future or Pre-Trial Post-Trial
  8. 8. Essential Elements1. LOSS OF EARNING CAPACITYa) Establish the earnings base/earning capacity (what was earned or could have been earned)b) Over Worklife Expectancy from date of injury  Source: • “The Markov Process Model of Labor Force Activity: Extended Tables of Central Tendency, Shape, Percentile Points, and Bootstrap Standard Errors” (Skoog & Ciecka) Journal of Forensic Economics 22(2), 2011, pp.165-229 © 2011 by the National Assoc. of Forensic Economics Gary R. Skoog, James E. Ciecka and Kurt V. Krueger
  9. 9. Essential Elements1. LOSS OF EARNING CAPACITYc) Inflation often removed from earnings increases (and correspondingly from the discount rate) under the “Constant Dollar” methodd) Earnings based on education, training & experience  Consider promotions & career ladder at employer  Age, health, intelligence & record of employment
  10. 10. Essential Elements1. LOSS OF EARNING CAPACITYf) Deduct the mitigating earnings still able to earng) Taxes are not usually deductedh) Injury or death of a child  No work history and usually not married & no children  Project earnings based upon a survey of family educational background and socio-economic status
  11. 11. Joan Smith 10-30-95 12-20-06 Gregory Smith - Father Allison Smith - Mother BA - Business Assoc Degree Assoc Degree / Navy Asst Mgr – Diet Consultant District Market Mgr ($50,000) Carol Nesmith (sister) (Nashville, TN) Susan White (sister) David Smith (brother) PhD – Law Assoc – Applied Science (Deerfield Beach, FL) BS – Nursing / Assoc – Applied Sciences Certified Diagnostic SonographyMS – Computer IS / BA – Accounting Atty at Law ($50,000) RT(R),RDMS,RVT,RCS ($91,000) Chief Ops Officer ($100,000) Thomas Nesmith (brother-in-law) Mike White (brother-in-law) (Age 39) Margaret Smith (sister-in-law) PhD – Medicine BA – Marketing BA – Journalism BS – Biology Assoc – Electronic Tech Special Events Coordinator Chief of Vascular Surgery ($800,000) Facility Ops Spvr ($57,000) Eugene Smith Alma Sue Elway Thomas Elway BS – Econ/Fin Wilma Jean Smith Assoc Degree BA – Sociology PhD – Veterinary / Army MA – Education Teacher / Child Care Provider Teacher / Social Case Worker Medical Officer – US Dept Agr ($73,000) Bus/IT Instructor ($100,000) Sara Smith RE Smith BA – Education Owner / Operator Teacher RT Smith Lumber Company Elijah Smith Raymond Smith MS - Business Owner / Operator BA – Business RT Smith Lumber Company Business Manager
  12. 12. Joan SmithFamily Member Education and Income Summary Annual Value Annual Value Annual Weekly in Indexed to FutureOccupation SOC Co d e Wage Salary and Education Attainment Table** Hours 2005 Dollars Future Year YearAttorney 2 3 10 11 50,000 Wage and Salary Workers (Part-Time) High School 20 12,818 14,019 2014Business Manager 119 19 9 65,430 * Wage and Salary Workers (Full-Time) Some College 40 29,640 33,068 2016Business/IT Instructor 2 510 11 100,000 Wage and Salary Workers (Full-Time) Bachelors 40 42,276 48,114 2018Certified Diagnostic Sonography 2 9 112 4 91,000 Wage and Salary Workers (Full-Time) Bachelors/Advanced 40 51,116 60,537 2022Chief of Vascular Surgery 2 9 10 6 7 800,000Chief Operating Officer 1110 11 100,000 **Current Population Survey, U.S. Department of Labor, Bureau of Labor Statistics, T able 17: Median usual weekly earningsCPA 13 2 0 11 43,650 * of full-time wage and salary workers 25 years and over by educational attainment and sex, 2005 annual averages.Diet Consultant 2 9 10 3 1 40,080 *District Market Manager 112 0 2 2 50,000Electrical Engineer 172 0 71 59,730 *Facility Operations Supervisor 119 19 9 57,000 The use of government statistical wage and salary earnings is justifiedMarketing Manager 112 0 2 1 89,380 * given that the family history of annual earnings on average is in fact higher.Medical Office Manager 119 111 66,740 *Medical Officer 119 111 73,000Owner / Operator 1110 2 1 50,000 *Owner / Operator 1110 2 1 50,000 *Special Events Coordinator 13 112 1 42,230 *Teacher 2 52 0 2 1 45,560 *Teacher 2 52 0 2 1 45,560 *Teacher / Child Care Provider 2 53 0 9 9 34,540 *Teacher / Social Case Worker 2 53 0 9 9 34,540 *VP of Marketing 112 0 2 1 126,470 *Average Annual Wage 96,132*Occupational wage information provided by U.S. Department of Labor, Bureau of Labor Statistics, May 2005, Annual Median Wage, Area T N-MS-AR; otherwise by family members. Degree(s) Held by Family Members High School Associates Bachelors Advanced 22 6 18 9 100% 27% 82% 41%
  13. 13. Essential Elements1. LOSS OF EARNING CAPACITYh) Sources of Income Data:  W-2s, 1040s, paystubs, depos of family  Government surveys and statistics • Bureau of Labor Statistics, Department of Labor, “Occupational Employment Statistics (OES) Survey” http:/stat.bls.gov/oes/home.htm • US Dept. of Commerce, Bureau of the Census: “Money Income of Households…Money Earnings by Sex, Age & Education,” & “US Industry & Trade Outlook”
  14. 14. Essential Elements1. LOSS OF EARNING CAPACITYh) Sources of Income Data (cont’d):  A vocational rehabilitation expert (also: impairment)  Industry specific • Accounting: American Institute of CPAs, Robert Half & Assoc. • Legal: ABA, Altman Weil, Inc., FindLaw.com • Medical: AMA, Medical Group Management Assoc., Medical Economics • Military: Military.com
  15. 15. Essential Elements1. LOSS OF EARNING CAPACITYi) Personal Consumption - in WD cases, generally subtract a % (might justify the lower Personal Maintenance)  Purchases made by an individual family member exclusively for his or her own benefit, such as haircuts, food, clothes, toiletries, jewelry, medical expenses, etc.  The amount of income that would have gone toward the consumption of the decedent is usually subtracted from the projected lost income
  16. 16. Essential Elements1. LOSS OF EARNING CAPACITYi) Personal Consumption (cont’d)  Assumptions often made for the number of persons in a household as this impacts the % consumed  Income level usually affects the % consumed  Source: • “Patton-Nelson Personal Consumption Tables 2005-06” Journal of Forensic Economics 20(3), 2007, pp. 217-225 ©2009 by the National Assoc. of Forensic Economics Michael R. Ruble, Robert T. Patton, and David M. Nelson
  17. 17. Essential Elements2. LOSS OF FRINGE BENEFITSa) Part of the job or occupationb) Expressed in the calculation as a % of gross lost Earning Capacityc) Can be 20% - 40%
  18. 18. Essential Elements2. LOSS OF FRINGE BENEFITSc) Examples: 11.7% Employer paid FICA, Unemployment & Worker’s Comp. (Legally-Required) 11.6% Health & Other Insurance 3.0% Retirement Plans 9.8% Employer paid Holidays & Vacations ? On-site Child Care & Meals 36.1%
  19. 19. Traditional Fringe Benefits-Private IndustryBureau of Labor Statistics Economic News Release, June 7, 2012, "Employer Costs for Employee Compensation",March 2012, Table A. Relative importance of employer costs for employee compensation, All Workers.Private Industry Paid leave 9.8% Health Insurance 11.0% Other Insurance 0.6% Defined contribution plan 3.0% Legally required 11.7% Percentage of Wages 36.1% Civilian Workers Private Industry Comp. Comp. Component % of Wages Component % of Wages Wages and salaries 69.3% 70.3% Benefits 30.7% 29.7% 100.0% 100.0% Paid leave 7.0% 10.1% 6.9% 9.8% Supplemental pay 2.4% 3.5% 2.9% 4.1% Health Insurance 8.5% 12.3% 7.7% 11.0% Other Insurance 0.4% 0.6% 0.4% 0.6% Defined benefit plan 2.8% 4.0% 1.5% 2.1% Defined contribution plan 1.8% 2.6% 2.1% 3.0% Legally required 7.8% 11.3% 8.2% 11.7% 30.7% 44.4% 29.7% 42.3%
  20. 20. Essential Elements2. LOSS OF FRINGE BENEFITSd) Sources of fringe benefit data:  Interview or depo of employer or family  Government & private surveys & statistics • U.S. Department of Labor, the Bureau of Labor Statistics, in a study titled "Employer Costs for Employee Compensation, June 7, 2012 • U.S. Research and Analysis Center, U.S. Chamber of Commerce , "The 2008 Employee Benefits Study"
  21. 21. Essential Elements2. LOSS OF FRINGE BENEFITSe) Unvested or unconventional benefits  Lucrative defined benefit pension plans  Stock options  Stock performance awards  Unfunded retirement plans  Deferred compensation plans  Use of company vehicles
  22. 22. Essential Elements3. LOSS OF HOUSEHOLD SERVICESa) Services that can no longer be performed due to injury or deathb) Not just for the loss of a homemakerc) Include unpaid tasks that maintain and enhance the lives of those in household  Cooking, Cleaning, Lawn care, Child care & transportation, Home & vehicle maintenance & repairs, Gardening, Shopping, etc.
  23. 23. Essential Elements3. LOSS OF HOUSEHOLD SERVICESd) The loss, even though not directly compen- sated like regular employment, has value to the family nonetheless since the tasks will:  Not be done at all or not as often  Be done by someone else in the household (at the expense of other things the "someone else" might have been doing)  Require outside assistance who may have to be compensated
  24. 24. Essential Elements3. LOSS OF HOUSEHOLD SERVICESe) Valuation methods are generally based on hours spent times an hourly rate  Opportunity Cost Method (reference to what the individual could have earned in the marketplace)  Replacement Cost Method (reference to the cost to hire in the marketplace)f) Over the life expectancy  Source: National Vital Statistics Reports
  25. 25. Essential Elements3. LOSS OF HOUSEHOLD SERVICESg) Most do not keep a log of hours spent on household choresh) Source:  “The Dollar Value of a Day”, Expectancy Data (estimated hours by chore along with hourly rates)  www.expectancydata.com
  26. 26. Table 6. Married males that work full-time, wife does not work, youngest child ages 13 to 17 Dollar Weekly Waking Hours Standard Weekly Hourly Participation Value Secondary With Error Time Use Category Hours Value At Home Rate of a Day Child Care Family PercentInside Housework 0.87 $10.33 $1.28 0.00 0.46 0.87 14.6% 21.1%Food Cooking & Clean-up 1.29 9.86 1.81 0.00 0.80 1.10 30.1 15.5Pets, Home & Vehicles 5.05 12.11 8.74 0.00 2.01 4.81 38.9 9.2Household Management 0.76 15.02 1.63 0.00 0.38 0.58 25.4 15.8Shopping 1.78 11.46 2.91 0.00 1.19 0.13 32.1 11.2Obtaining Services 0.10 13.18 0.18 0.00 0.02 0.05 2.3 26.4Travel for Household Activity 1.81 11.96 3.09 0.00 1.09 0.01 40.2 7.9 Household Production 11.65 11.81 19.65 0.00 5.95 7.55 78.3 5.6Household Children 1.26 11.01 1.99 n/a 1.08 0.56 22.3 18.4Household Adults 0.17 11.23 0.28 0.00 0.15 0.12 5.7 51.2Non-Household Members 0.68 11.39 1.10 0.00 0.42 0.27 8.5 32.2Travel for Household Members 0.63 13.15 1.18 0.00 0.47 0.00 15.4 10.6Travel for Non-Household Members 0.30 13.15 0.56 0.00 0.17 0.00 8.0 19.5 Caring and Helping 3.04 11.76 5.10 0.00 2.30 0.96 30.8 11.5 Table 35. Married females that are not in the labor force and not disabled, husband works, youngest child under age 13 Dollar Weekly Waking Hours Standard Weekly Hourly Participation Value Secondary With Error Time Use Category Hours Value At Home Rate of a Day Child Care Family PercentInside Housework 12.29 $10.33 $18.14 8.75 6.21 11.99 79.6% 1.9%Food Cooking & Clean-up 9.98 9.86 14.06 7.93 5.72 9.80 89.4 1.2Pets, Home & Vehicles 2.39 12.11 4.13 1.74 1.51 2.13 24.0 4.2Household Management 1.48 15.02 3.17 1.00 0.85 1.25 30.1 4.5Shopping 4.99 11.46 8.17 3.32 3.78 0.09 55.0 2.4Obtaining Services 0.22 13.18 0.42 0.14 0.11 0.16 5.5 12.3Travel for Household Activity 2.81 11.96 4.81 1.90 2.23 0.07 58.1 2.4 Household Production 34.16 10.84 52.89 24.79 20.40 25.49 98.1 1.0Household Children 19.94 11.01 31.37 n/a 19.42 16.95 88.4 1.3Household Adults 0.24 11.23 0.38 0.13 0.19 0.13 7.9 12.6Non-Household Members 0.74 11.39 1.21 0.38 0.59 0.16 13.6 10.5Travel for Household Members 2.24 13.15 4.21 0.18 1.83 0.03 44.4 2.1Travel for Non-Household Members 0.37 13.15 0.69 0.20 0.27 0.00 11.5 5.0 Caring and Helping 23.54 11.26 37.87 0.89 22.30 17.27 89.9 1.2 “The Dollar Value of a Day”, 2003
  27. 27. Essential Elements4. MEDICAL AND REHABILITATION BILLSa) Bills already incurredb) Estimated future bills from a Life Care Plan  Indexed using the Medical Price Index rather than the general Consumer Price Indexc) Present valuing a Life Care Plan is often a separate engagement
  28. 28. Essential Elements5. DISCOUNT ALL LOSSES TO PRESENT VALUEa) Pre-Trial Losses  Calculate losses prior to Trial Date (past) and compound with interest to Present Value -1 Trial Date +1 +2 +3
  29. 29. Essential Elements5. DISCOUNT ALL LOSSES TO PRESENT VALUEb) Post-Trial Losses  Calculate losses after Trial Date (future) and discount to Present Value -1 Trial Date +1 +2 +3
  30. 30. Essential Elements5. DISCOUNT ALL LOSSES TO PRESENT VALUEc) Discount Rate  Using a “risk-free” rate (U.S. Treasury Bonds)  The “best and safest investments” as per Jones and Laughlin Steel Corporation v. Howard E. Pfeifer (462 U.S. 523; 1983; US Supreme Court)  Inflation often removed from the discount rate (and correspondingly from earnings increases ) under the “Constant Dollar” method  “Real” rate of interest thought to be around 2-3%
  31. 31. Bring the 5 Essential Elements Together Wrongful Death Economic Damages Report Case Information Plaintiff James Smith "Injury" Date 08/23/2011 Sex Male Age at Injury 41.4 Race White Injury Year Fraction 0.36 Birthdate 03/25/1970 Life Expectancy 38.1 Worklife Expectancy 23.0 Age at End of Life Expectancy 79.5 Retirement Age 64.4 End of Life Date 9/28/2049 End of Worklife Date 8/22/2034 Life Date Fraction 0.46 Worklife Year Fraction 0.36 Valuation Date 04/13/2013 Discount Rate 1.8% Assumed "Trial" Date 04/13/2013 Trial Year Fraction 0.28 Damages Summary Future Values Present Values Type of Damage Past Future Past Future Income Loss 139,551 2,001,670 139,551 1,645,826 Fringe Benefits Loss 62,473 960,200 62,473 785,952 Household Production Loss 13,871 482,172 13,871 331,166 Future Medical Costs 0 0 0 0 Total Damages 215,895 3,444,042 215,895 2,762,944 Grand Total Damages 3,659,937 2,978,838 Rounded 2,979,000
  32. 32. Lost Earnings, Fringe Benefits, Household Services and Future Medical CostsExhibit A Fringe Benefits Household ServicesPre-Trial Earnings See Ex. D See Ex. C Total Annual Loss Pres. Net Net Plaintiff Personal Plaintiff Plaintiff Fringe Fringe Service Bal. Year Value Earnings Discount Would Have Cons. Earnings Earnings Would Have Did/Will Benefit Benefit Value Service Pres. Value Pres. Val. Ending Year Growth Rate Earned See Ex. B Loss Pres. Value Earned Earn Loss Pres. Value Loss Pres. Value Total Loss Total Loss Total Loss12/31/2011 0 3.1% 1.80% 36,894 (7,159) 29,735 29,735 13,319 0 13,319 13,319 3,040 3,040 46,093 46,093 46,09312/31/2012 0 3.1% 0.00% 105,659 (20,502) 85,157 85,157 38,143 0 38,143 38,143 8,443 8,443 131,743 131,743 177,83604/13/2013 0 3.1% 1.80% 30,502 (5,842) 24,660 24,660 11,011 0 11,011 11,011 2,388 2,388 38,059 38,059 215,895Total Pre-Trial 173,054 (33,503) 139,551 139,551 62,473 0 62,473 62,473 13,871 13,871 215,895 215,895Post-Trial04/13/2014 1 1.0% 1.80% 112,311 (21,328) 90,983 89,374 40,544 0 40,544 39,827 8,615 8,463 140,142 137,664 353,55904/13/2015 2 1.0% 1.80% 113,434 (21,541) 91,893 88,672 40,950 0 40,950 39,514 8,701 8,396 141,544 136,582 490,14104/13/2034 21 1.0% 1.80% 137,040 (37,746) 99,294 68,268 49,471 0 49,471 34,013 10,511 7,227 159,276 109,509 2,775,53804/13/2035 22 1.0% 1.80% 49,828 (13,724) 36,104 24,384 17,988 0 17,988 12,149 10,618 7,171 64,710 43,704 2,819,24204/12/2036 23 0.0% 1.80% 0 0 0 0 0 0 0 0 17,538 11,635 17,538 11,635 2,830,87704/13/2037 24 0.0% 1.80% 0 0 0 0 0 0 0 0 17,714 11,544 17,714 11,544 2,842,42104/13/2038 25 0.0% 1.80% 0 0 0 0 0 0 0 0 17,889 11,452 17,889 11,452 2,853,87404/13/2039 26 0.0% 1.80% 0 0 0 0 0 0 0 0 18,065 11,360 18,065 11,360 2,865,23404/12/2040 27 0.0% 1.80% 0 0 0 0 0 0 0 0 18,240 11,268 18,240 11,268 2,876,50204/13/2041 28 0.0% 1.80% 0 0 0 0 0 0 0 0 18,428 11,183 18,428 11,183 2,887,68404/13/2042 29 0.0% 1.80% 0 0 0 0 0 0 0 0 18,615 11,096 18,615 11,096 2,898,78104/13/2043 30 0.0% 1.80% 0 0 0 0 0 0 0 0 18,802 11,010 18,802 11,010 2,909,79004/12/2044 31 0.0% 1.80% 0 0 0 0 0 0 0 0 18,989 10,922 18,989 10,922 2,920,71304/13/2045 32 0.0% 1.80% 0 0 0 0 0 0 0 0 19,176 10,835 19,176 10,835 2,931,54804/13/2046 33 0.0% 1.80% 0 0 0 0 0 0 0 0 19,364 10,748 19,364 10,748 2,942,29504/13/2047 34 0.0% 1.80% 0 0 0 0 0 0 0 0 19,562 10,666 19,562 10,666 2,952,96104/12/2048 35 0.0% 1.80% 0 0 0 0 0 0 0 0 19,761 10,584 19,761 10,584 2,963,54504/13/2049 36 0.0% 1.80% 0 0 0 0 0 0 0 0 19,960 10,501 19,960 10,501 2,974,04609/28/2049 37 0.0% 1.80% 0 0 0 0 0 0 0 0 9,273 4,792 9,273 4,792 2,978,838Total Post-Trial 2,659,834 (658,164) 2,001,670 1,645,826 960,200 0 960,200 785,952 482,172 331,166 3,444,042 2,762,944 Grand Totals 2,832,888 (691,667) 2,141,221 1,785,377 1,022,673 0 1,022,673 848,425 496,043 345,037 3,659,937 2,978,838
  33. 33. Personal ConsumptionExhibit B Earnings Pres. Net Plaintiff Spouse Total Pct. Of Year Value Earnings Would Have Will Family Personal Personal Ending Year Growth Earned Earn Earnings ConsumptionConsumption12/31/2011 0 3.1% 36,894 27,599 64,493 11.1% (7,159)12/31/2012 0 3.1% 105,659 79,041 184,700 11.1% (20,502)04/13/2013 0 1.0% 30,502 22,131 52,633 11.1% (5,842)04/13/2014 1 1.0% 112,311 79,830 192,141 11.1% (21,328)04/13/2031 18 1.0% 133,010 94,543 227,553 16.1% (36,636)04/12/2032 19 1.0% 134,340 95,488 229,828 16.1% (37,002)04/13/2033 20 1.0% 135,683 96,443 232,126 16.1% (37,372)04/13/2034 21 1.0% 137,040 97,407 234,447 16.1% (37,746)04/13/2035 22 1.0% 49,828 35,417 85,245 16.1% (13,724)04/12/2036 23 1.0% 0 0.0% 004/13/2037 24 0.0% 0 0.0% 004/13/2038 25 0.0% 0 0.0% 004/13/2039 26 0.0% 0 0.0% 004/12/2040 27 0.0% 0 0.0% 004/13/2041 28 0.0% 0 0.0% 004/13/2042 29 0.0% 0 0.0% 004/13/2043 30 0.0% 0 0.0% 004/12/2044 31 0.0% 0 0.0% 004/13/2045 32 0.0% 0 0.0% 004/13/2046 33 0.0% 0 0.0% 004/13/2047 34 0.0% 0 0.0% 004/12/2048 35 0.0% 0 0.0% 004/13/2049 36 0.0% 0 0.0% 009/28/2049 37 0.0% 0 0.0% 0 Grand Totals 2,832,888 (691,667)
  34. 34. Lost Production of Household ServicesExhibit C Pre-Injury Post-Injury Year Pres. Hours Total Hours Total Lost Present Ending Value Year Status Weekly Pay Rate Services Weekly Pay Rate Services Services Value12/31/2011 0 A 13.8 11.80 3,040 0.0 11.80 0 3,040 3,04012/31/2012 0 A 13.8 11.80 8,443 0.0 11.80 0 8,443 8,44304/13/2013 0 A 13.8 11.92 2,388 0.0 11.92 0 2,388 2,38804/13/2014 1 A 13.8 12.04 8,615 0.0 12.04 0 8,615 8,46304/13/2031 18 A 13.8 14.26 10,203 0.0 14.26 0 10,203 7,40104/12/2032 19 A 13.8 14.40 10,303 0.0 14.40 0 10,303 7,34104/13/2033 20 A 13.8 14.54 10,404 0.0 14.54 0 10,404 7,28204/13/2034 21 A 13.8 14.69 10,511 0.0 14.69 0 10,511 7,22704/13/2035 22 A 13.8 14.84 10,618 0.0 14.84 0 10,618 7,17104/12/2036 23 B 22.5 14.99 17,538 0.0 14.99 0 17,538 11,63504/13/2037 24 B 22.5 15.14 17,714 0.0 15.14 0 17,714 11,54404/13/2038 25 B 22.5 15.29 17,889 0.0 15.29 0 17,889 11,45204/13/2039 26 B 22.5 15.44 18,065 0.0 15.44 0 18,065 11,36004/12/2040 27 B 22.5 15.59 18,240 0.0 15.59 0 18,240 11,26804/13/2041 28 B 22.5 15.75 18,428 0.0 15.75 0 18,428 11,18304/13/2042 29 B 22.5 15.91 18,615 0.0 15.91 0 18,615 11,09604/13/2043 30 B 22.5 16.07 18,802 0.0 16.07 0 18,802 11,01004/12/2044 31 B 22.5 16.23 18,989 0.0 16.23 0 18,989 10,92204/13/2045 32 B 22.5 16.39 19,176 0.0 16.39 0 19,176 10,83504/13/2046 33 B 22.5 16.55 19,364 0.0 16.55 0 19,364 10,74804/13/2047 34 B 22.5 16.72 19,562 0.0 16.72 0 19,562 10,66604/12/2048 35 B 22.5 16.89 19,761 0.0 16.89 0 19,761 10,58404/13/2049 36 B 22.5 17.06 19,960 0.0 17.06 0 19,960 10,50109/28/2049 37 B 22.5 17.23 9,273 0.0 17.23 0 9,273 4,792 496,043 0 496,043 345,037

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