VOCATIONAL EXPERT:
Richard H. Andersen, M.S., C.V.E., C.R.C., C.D.M.S., of VECTOR, Inc.
Tamorah Hunt of Formuzis, Pickersgill & Hunt, (714) 542-8853 served as economist.

CASE BACKGROUND:
Plaintiff, a 38 year old female with over 17 years of experience in the computer industry, was rear-ended by a van while she was stopped at a red light. She sustained multiple injuries and continued to suffer from chronic, constant pain in her low back and neck over 6 years after the incident. In addition, she continued to experience chronic headaches and chronic pain and spasms in her wrists. Plaintiff was also diagnosed with a depressive disorder.

FOCUS ISSUE:
This case was unique for two reasons: Plaintiff was unemployed at the time of the incident and she had a pre-existing disability from a previous automobile accident. Andersen interviewed the plaintiff and reviewed her medical records, ultimately determining she had an 11% future loss of earning capacity on a pre-incident basis, but had the potential, prior to subject incident, to secure employment in the computer industry. He opined she would have held a position similar to a Computer Operator or User Support Analyst. Post-incident, Plaintiff was working as a selfemployed Tax Preparer (with help from family members) and no longer had the potential to work in the computer industry.

TESTIMONY:
Andersen provided testimony on several aspects. Medical documentation, information gathered from the vocational interview, and vocational test results all played a role in his final assessment. The test results, for example, provided much insight into the impact of Plaintiff’s injuries. Plaintiff completed vocational testing in 2005 and 2007. A comparison between the results found she had declined over the two years. In 2007, she received negligible results on 6 out of 10 tested aptitudes, as opposed to negligible results on 4 out of 10 aptitudes in 2005. Andersen compared Plaintiff’s 2007 aptitudes with those required of Computer Operators, according to U.S. Department of Labor standards. He found she was not able to perform at the required levels in 7 out of 10 aptitudes. More surprising was a comparison between Plaintiff’s 2007 aptitudes and those required of Tax Preparers, which confirmed she was also not able to perform at the required levels in 7 out of 10 aptitudes (see graph).

Andersen’s analysis led to his conclusion that Plaintiff was not only unable to return to work in the computer industry, but she would experience a reduced work life expectancy in her current role as a self-employed Tax Preparer (see graph). It was highly probable that the plaintiff would exit the labor market up to 14 years before the standard retirement age of 65.

ABOUT RICHARD ANDERSEN:
Richard Andersen holds national certifications as a Rehabilitation Counselor, Vocational Evaluator and Disability Management Specialist, with 37 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, medical malpractice, wrongful death, and 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.