SITUATION:
Plaintiff was on vacation at age 57 when he sustained multiple bodily injuries from a car collision. Injuries included deep lacerations of the right ear area, fractured rib, contusion of the right lung and a right shoulder wound. At the time of the injury, Plaintiff had worked 23 years as a Machine Operator/Forklift Driver for the same company. He planned to retire at age 65. Due to the physical requirements of his pre-injury occupation, he now found himself unable to return to the same work conditions. In addition to his physical limitations, Plaintiff had been functioning at a low educational level. He could not read or write in English, and his Spanish skills were also weak: reading at less than the 4th grade level and spelling at the 5th grade level.
Andersen reviewed various medical and employment records while researching Plaintiff's occupational outlook. He determined that Plaintiff did sustain injuries that prevented him from returning to his pre-injury job, but his doctor had released him to sedentary work roughly 2 years after the incident at age 59. Plaintiff, now 62, had done nothing to mitigate his loss of earnings claim. At the time of his deposition, Andersen stated that Plaintiff could have already been employed at age 59 in an occupation that required little education and physical demand, if he would have sought employment. Andersen's research of 4 typical, unskilled jobs, for which Plaintiff could qualify, found 1698 employers within a 25 mile radius of the Plaintiff's residence that could be contacted for employment.
ABOUT RICHARD ANDERSEN:
Richard Andersen holds national certifications as a Rehabilitation Counselor, Vocational Evaluator and Disability Management Specialist, with 31 years experience in vocational rehabilitation. He has also testified in Superior Court in 10 California counties. VECTOR, Inc., specializes in vocational rehabilitation counseling, disability research and forensic rehabilitation services, including vocational expert testimony on personal injury, wrongful death, wrongful termination, ADA, Social Security, divorce and sexual harassment matters. The firm, founded in 1975, serves both plaintiff and defense attorneys, providing the link between the physician and the economist to precisely determine damages
