SLIDE 1 Disclaimer
This power point presentation is an
- example. Identities have been changed
to prevent disclosure of parties, case identification or results.
SLIDE 2
Our Client farmed accident-free for 65 years of his life.
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Until his first use of Defendant Company’s extender. . .
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then, Our Client was dismembered.
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How did it happen?
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Only PTO product in America sold without a shield or guard. No user instructions. No reasonable warning.
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Defendant Company violated:
ASAE S493: Guarding for Agricultural Equipment Requirements ASAE S318.13: Safety For Agricultural Field Equipment ASAE S441.3: Safety Signs ASAE S207.12: Operating Requirements for Power Take-off Driven Implements
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What are the consequences?
SLIDE 9
What are the consequences?
Right arm severed Left arm removed
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What are the consequences?
Right arm severed Left arm removed Stumps too short to accommodate meaningful prostheses
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Our client is unable to attend activities of daily living
Our client cannot
Roll over in bed
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Our client is unable to attend activities of daily living
Our client cannot
Cover himself with his sheet
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Our client is unable to attend activities of daily living
Our client cannot
Readily sit up to get in or out of bed
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Our client is unable to attend activities of daily living
Our client cannot
Perform bathroom functions
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Our client is unable to attend activities of daily living
Our client cannot
Turn pages to read
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Our client is unable to attend activities of daily living
Our client cannot
Adjust his glasses
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Our client is unable to attend activities of daily living
Our client cannot
Feed himself
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Our client is unable to attend activities of daily living
Our client cannot
Wash or bathe himself
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Our client is unable to attend activities of daily living
Our client cannot
Open or close doors
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Our client is unable to attend activities of daily living
Our client cannot
Dress himself
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Our client is unable to attend activities of daily living
Our client cannot
Walk safely on any irregular or slick surface
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Our client is unable to attend activities of daily living
Our client cannot
Get out of a plush chair
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Our client is unable to attend activities of daily living
Our client cannot
Touch his wife’s face
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Our client is unable to attend activities of daily living
Hug his Family
Our client cannot
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Our client is unable to attend activities of daily living
Be left alone for more than 2 hours
Our client cannot
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Our client is unable to attend activities of daily living
Our client cannot
Do things routinely taken for granted
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Economic Losses to Our client
Medical Expenses: $***,***.** Expected Additional Medical Expenses: $***,***.** Lost Earnings and Earning Capacity: $***,***.**
Total: $*,***,***.**
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Our client wouldn’t make this trade for $*,***,***. . .
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But he has no choice.