Amputation Demand Letter
VI. EVIDENCE OF DAMAGES
A. MEDICAL EVIDENCE
1. Synopsis of Personal Injuries
a. Grade IV open left tibia - fibula fracture.
b. Extensive degloving injury involving loss of most of the skin from the left knee to the ankle distally.
c. Devascularization of the left foot and lower leg.
d. Loss of motor function below left knee.
e. Loss of sensory function below left knee.
f. Compartment syndrome, left foot.
g. Progressive necrosis and gangrene of left foot and lower extremity.
h. Fractured left acetabulum.
i. Dislocated left thumb.
j. Traumatic brain injury.
k. Organic brain syndrome.
l. Damage to strip of cerebral cortex.
m. Damage to frontal lobe of cerebral cortex.
2. Sequelae of Personal Injuries
a. Guillotine below-the-knee amputation, left leg.
b. Phantom left leg and foot pain.
c. Major depression.
d. Reduced ability to process information.
e. Reduction in abstract reasoning.
f. Impairment in social judgment.
g. Impairment of verbal memory.
h. Impairment of visual memory.
i. Serious impact on hand-eye coordination skills.
j. Damage to cognitive functioning.
k. Damage/reduction in intellectual functioning.
l. Very high emotional distress.
m. Loss of manual grip strength.
n. Impaired verbal reasoning skills.
o. Overall language function impaired.
p. Damage to creative ability.
q. Permanent cognitive deficits.
r. Sinus tachycardia.
s. Scarring - left leg stump.
t. Scarring - right leg.
u. Scarring - donor sites.
v. Dysphoric mood and mood swings.
w. Social isolation and alienation.
x. Apathy.
y. Irritability.
z. Proximate memory loss.
aa. Difficulty in rhythm expression.
bb. Shortened attention span.
cc. Distractibility.
dd. Adjustment disorder with depressed mood.
ee. High level anxiety.
ff. Constricted life.
gg. Sleep disorder.
hh. Depressed libido.
ii. Amotivational.
jj. Nightmares.
kk. Flashbacks.
ll. Self-consciousness.
mm. Damage to vocal range.
rr. Accelerated aging process.
3. Prognosis for Future Complications
a. Prognosis - potential above-the-knee amputation.
b. Prognosis - deep depression.
c. Prognosis - suicidal ideation.
d. Prognosis - extreme apprehension about future.
4. Hospitalizations
a. Greater County Medical Center. Lindsey was taken from the scene of the collision to Greater County Medical Center where she was initially examined by Dr. Brandon Dennis, and admitted with a diagnosis of open fracture of the left tibia-fibula and a fractured left acetabulum. Based upon the nature and the extent of her injury, her prognosis was poor and her need for surgery immediate.
Lindsey was hospitalized at Greater County Medical Center for the next 41 days, during which time she underwent 14 surgical procedures; was transfused with 24 units of packed red blood cells; was treated by 25 doctors; endured more than 70 excruciatingly painful Dakins-dressing changes and incurred the majority of the $364,690.34 in medical expenses which she has sustained to date. Lindsey was very disturbed by the fact that during this six weeks of Hell which she was forced to endure as a result of the negligence of Jane Gingerstein, she never received flowers, a card, a phone call, or a visit from the woman who caused this tragedy.
b) The Century City Hospital - Lindsey was transferred on August 6, 1992 to Century City Hospital where she was admitted under the care of Dr. Athleo Gordon for multiple skin grafts and additional plastic surgery. Lindsey remained hospitalized at Century City until August 28, 1992, during which time she endured three additional surgical procedures and additional excruciatingly painful Dakins-dressing changes.
