Burns - Automobile Accident Demand Letter
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Automobile Accident
Demand Letter
B. HOSPITAL COURSE OF TREATMENT - SALLY
On August 28, 1996, Sally was admitted to Lakeside Hospital and immediately underwent the escharotomy, cutting through the tightened leathery, swollen burned skin to allow the blood to flow and save the tissues in the right arm and hand. A significant pneumothorax was noted on chest x-ray, so a chest tube was inserted into the right lung. Gas measurement taken revealed that the oxygen saturation was satisfactorily achieved.
On 7-29-96, Sally began having nasogastric tube feeding. Her respiratory status gradually worsened, so a pulmonary specialist was consulted to give expert advice and treatment during the hospital stay. A bronchoscopy was performed on August 30, 1996. Lung tissue samples were excised and although no abnormalities were found during the inspection through the bronchoscope, Sally developed ARDS, adult respiratory distress syndrome. Pulmonary infiltrates and fever spikes of 102 degrees caused the doctors to order strong antibiotics to counter the infection. ARDS is the complication which kills most burn victims, and Dr. Donald Parks will testify that Sally's life was hanging in the balance as she courageously fought to survive the combination of devastating burns, infection and Adult Respiratory Distress Syndrome. This jury will have the opportunity to fully appreciate what an incredibly courageous woman Sally Waymond is.
On August 31, 1996, the grafted skin had turned yellow and some superficial bleeding was noted in her hand. Since the burns had destroyed blood vessels in the skin, Dr. Parks was concerned that Sally's body was attempting to reject her grafts. Sally was taken to the operating room for skin excision of the burned skin, excision of the upper layers of her viable skin and grafting of the viable skin over the tissue over the remaining burned skin. Due to the loss of blood and her critical status, 250 cc's of blood were transfused.
On August 2, 1996, a chest x-ray revealed a tension pneumothorax on the left pleural side; therefore, Sally was taken to the operating room and a chest tube was placed in her left pleural cavity to reinflate the lung. At the same time, a bronchoscopy was performed to visualize the damage sustained to the trachea and bronchial structures. She remained on the mechanical ventilator and both chest tubes contained air leaks.
On August 3, 1996, a Swan-Ganz catheter was inserted into the superior vena cava and lodged in the pulmonary artery to more accurately monitor Sally's pressure and fluid status. Additionally, Sally had her right chest tube removed and another right chest tube was punctured into her right chest. Dr. Mario Kapusta performed a thoracotomy after it was discovered that Sally had sustained a lower lung lobe laceration.
After her extubation on August 7, 1996, the skin grafts were meshed. Dr. Parks describes grafts put through a machine that punches holes in the graft so that it can spread out and cover a larger area of the burned skin. The graft sites were covered with silver sulfadiazine because the infection rate ten days to two weeks after the injury was rampant.
Dr. Parks states that this is the time period where he was very concerned about infection because this dead tissue will in fact grow out may types of bacteria which can get into the blood stream and ultimately kill the patient. (DP 8) Sally was taken to the operating room for debridement of the crusted skin and excision of her viable skin for grafting over the open wounds of her left hand, wrist, forearm elbow, upper arm and left anterior thigh. She remained intubated and connected to a mechanical ventilator until August 10, 1996.
A regimented program for rehabilitation began on August 13, 1996, however, her condition remained critical in the intensive care unit of the burn center.
On August 19, 1996, Sally returned for an operation which included excision of her viable skin for grafting over her right lateral leg, knee, right and left upper arm. Of note were the deep burns over the proximal interphalangeal joints, middle phalanges of the right, index, long ring and little fingers. The doctors determined that due to the depth of the burns and failure of viable skin to grow into it, the finger and joints would require pinning as well as more debridement over time.
On August 23, 1996, Sally was taken to the operating room for insertion pinning of the K-wires in her right hand in the proximal interphalangeal joints, right index, long, ring and little finger. She endured daily dressing changes with Excellent grafting over all of her skin grafts, with the exception of the right hand and fingers.
From August 23 until August 28, an aggressive occupational and physical therapy program was begun to restore the strength in Sally's muscles. Dr. Parks stated that Sally cooperated so she could be with her daughter and family who had been critically burned and were in the burn center in Smithville
On August 31, 1996, Dr. Parks requested Dr. Arthur Tarbox, licensed clinical psychologist, to evaluate Sally's depression concerning her tragedy. Sally was finally discharged from Lakeside Hospital to join her severely burned daughter at the Burn Clinic at St. Stephen Burn Institute in Smithville. Sally was greatly concerned over the fact that her nine-year-old daughter had to endure the agonies of treatment for burns over eighty-five percent of her body alone since her father and brother were killed and her mother was hospitalized. Also, during Sally's hospitalization, her husband and son were buried without Sally having the opportunity to pay her final respects. It will require several days of testimony to cover in detail the horrors that have been visited upon Sally Waymond as a result of this unnecessary conflagration and incineration of her family.
C. SURGICAL PROCEDURES - SALLY
The medical services rendered by the LifeFlight emergency team of Lakeside Hospital were remarkable. They not only saved Sally's life, but also performed state-of-the-art skill in the skin grafting techniques under the supervision of one of Orchard's outstanding board certified plastic surgery specialists, Donald Parks, M.D. Hospital records support and medical research reveals the impact of Sally's devastating burn injuries, such as, permanent scarring, neuropsychological trauma, pain and suffering, mental anguish, disability, and brutal disfigurement. Additionally, Sally experienced tremendous grief over the death of her husband and son and anxiety over her burned daughter and niece, hospitalized in St. Stephen Burn Institute in Smithville.
In order to overcome the neuropsychological component, Sally is in serious need of long term psychotherapy. Dr. Parks states that Sally will need rehabilitation care and counseling in order to adjust her life to return to be a productive member of society.
1. DATE: 7-28-96
DIAGNOSIS: Increasing evidence of edema and eschar contraction of right arm, forty-three percent (43%) total body surface area second and third-degree thermal flame burn and severe smoke inhalation injury.
PROCEDURE: Escharotomy of right arm. Dr. Parks states that Sally was awake and alert, but in extremely critical condition. (DP 1) She underwent numerous examinations and emergency treatment for monitoring her hemodynamic status. Sally had burns over forty-three percent (43%) of her total body, the majority of which were third degree, indicating virtually all layers of the skin had been destroyed. Dr. Parks notes that if she did survive the first few days, numerous surgeries would be necessary. (DP 2)
The burns on Sally's right arm were so deep that in fact it was obstructing the flow of blood from her heart down to her hand. An escharotomy was performed by electrocauterizing and cutting the right upper arm to the wrist and from the wrist back over the hand. Dr. Parks was able to release the pressure on the blood vessels in the arm allowing blood to flow freely into the hand to maintain its viability. This emergency surgery was necessary because the obstruction of the flow of blood was caused by the swelling of the firm, tight and leathery, dead burned tissue. (DP 3,4)
DOCTORS: Dr. Donald Parks
2. DATE: 7-28-96
DIAGNOSIS: Significant pneumothorax of right lung, forty-three percent (43%) total body surface area second and third degree thermal flame burn and severe smoke inhalation injury.
PROCEDURE: Chest tube insertion or tube thoracostomy entailed cutting into the right chest wall and allowing the air and fluid to escape. The chest tube was sutured to Sally's chest and connected to an underwater seal drainage jar or suctioning device to remove the poisons. Re-expansion of the lung was confirmed with chest x-ray, whereupon the chest tube could be removed.
DOCTORS: Dr. Mario Kapusta
3. DATE: 7-30-96
DIAGNOSIS: Adult Respiratory Distress Syndrome, forty-three percent (43%) total body surface area second and third-degree thermal flame burn and severe smoke inhalation injury
PROCEDURE: Bronchoscopy. The physicians passed a metal tube through Sally's nose, larynx and trachea into her lungs. Inspection of the lungs was visualized and samples of lung tissue and mucous were extracted.
DOCTORS: Dr. Mario Kapusta
4. DATE: 7-31-96
DIAGNOSIS: Forty-three percent (43%) total body surface area second and third-degree thermal flame burn and severe smoke inhalation injury.
PROCEDURE: Excision cutting of charred skin on the right hand, wrist, forearm, elbow and upper arm. Excision of live tissue for skin grafts from multiple skin sites on both lower legs, and scattered areas on Sally's buttocks. Skin grafts were applied with gauze, scarlet red application was made to donor sites, wound areas were dressed with silver sulfadiazine dressing. Due to loss of blood, 250 cc's of blood was transfused into her veins.
DOCTORS: Dr. Donald Parks
Dr. Agnieszka Pawlak
Dr. Tracy Rukab
Dr. Antonio Castaneda
Dr. Andrea Jarma
5. DATE: 8-2-96
DIAGNOSIS: Tension pneumothorax, forty-three percent (43%) total body surface area second a third-degree thermal flame burn and severe smoke inhalation injury.
PROCEDURE: Insertion of left chest tube involved cutting a hole into Sally's chest wall and allowing the air and fluid to escape. The chest tube was sutured to Sally's chest wall and connected to an underwater seal drainage jar to remove the toxins. Re-expansion of the lung is confirmed upon chest x-ray, whereupon the chest tube may be removed.
DOCTORS: Dr. Mario Kapusta
6. DATE: 8-2-96
DIAGNOSIS: Tension pneumothorax, forty-three percent (43%) total body surface area second and third-degree thermal flame burn and severe smoke inhalation injury.
PROCEDURE: Bronchoscopy. The physicians passed a metal tube through Sally's nose, larynx and trachea into her lungs. Inspection of the lungs was visualized and samples of lung tissue and mucous were extracted.
DOCTORS: Dr. Mario Kapusta
7. DATE: 8-3-96
DIAGNOSIS: Tension pneumothorax, forty-three percent (43%) total body surface area second and third-degree thermal flame burn and severe smoke inhalation injury.
PROCEDURE: Insertion of right angle chest tube. Tube thoracostomy involved cutting into Sally's chest wall and allowing the air and any fluid to escape. The chest tube was sutured to her chest wall and connected to an underwater seal drainage suctioning device to remove the fluid. This procedure should allow for re-expansion of the lung which should be confirmed with chest x-ray. After the lung is reinflated the chest tube may be removed.
DOCTORS: Dr. Mario Kapusta
8. DATE: 8-9-96
DIAGNOSIS: Status post left tension pneumothorax with persistent air leak following chest tube insertion, forty-three percent (43%) total body surface area second and third-degree thermal flame burn and severe smoke inhalation injury.
PROCEDURE: Left anterior lateral thoracotomy with primary repair of left lower lobe laceration. Due to the left lung failure to re-expand, exploratory surgery was performed to view the lung. Sally was taken to the operating room and surgeons cut into the intercostal space between the ribs. Saline solution was poured into the pleural cavity to view bubbles which signaled an air leak and lung laceration. The tear was finally located and stitch repaired to close the wound. After no further evidence of saline bubbles, Sally's lung, pleura, ribs and chest wall were stitched closed. Chest tubes were inserted to reinflate her lungs and attached to an underwater seal.
9. DATE: 8-9-96
DIAGNOSIS: Forty-three percent (43%) total body surface area thermal flame burn, twenty-five percent (25%) third degree, with Adult Respiratory Distress Syndrome.
PROCEDURE: Debridement of left hand, wrist, forearm, elbow and upper arm and left anterior thigh. Excision viable skin from donor sites of posterior thighs and posterior calves bilaterally as well as right flank for a total graft of 1150 cm2 of skin.
DOCTORS: Dr. Donald Parks
Dr. Agnieszka Pawlak
Dr. Timothy Sehorn
Dr. Antonio Castaneda
10. DATE: 8-19-96
DIAGNOSIS: Forty-three percent (43%) total body surface area thermal flame burn, twenty-five percent (25%) third degree, with smoke inhalation.
PROCEDURE: Excision and cutting off of charred skin of right lateral leg, knee, right and left upper arm. Excision of viable skin in right and left thigh donor sites and split-thickness skin grafting over excision sites. Debridement of residual crusting of skin. Excision of charred skin on the dorsum of the index, long, ring and little fingers of the right hand. However, satisfactory grafting surface could not be obtained and exposure of the interphalangeal joints was noted. (Bates 0429)
DOCTORS: Dr. Donald Parks
Dr. Agnieszka Pawlak
Dr. Antonio Castaneda
Dr. Timothy Sehorn
11. DATE: 8-23-96
DIAGNOSIS: Thermal deep burns forty percent (40%), with pending exposure of proximal interphalangeal joint, middle phalanges of the right index, long, ring and little fingers.
PROCEDURE: Debridement of thermal burns residue crusting of right thigh, knee, leg and bilateral upper arms with medicated dressings applied. Pinning insertion of K-wires into the proximal interphalangeal joint, right index, right long, right ring and little finger.
DOCTORS: Dr. Donald Parks
Dr. Agnieszka Pawlak
Dr. Daniel Freet
Dr. Timothy Sehorn
Dr. Charles Polsen
D. PERMANENT DAMAGE - SALLY
Three weeks after her initial discharge, Dr. Parks noted that after the pin removal from her fingers, there was healing but massive scarring, no normal tissue was seen on her arms, small open areas on the tops of her fingers existed and total destruction of all the fingernails, leaving thick, heavy scar tissue. (DP 10)
On September 12, 1996, and October, 1996, Dr. Parks saw Sally and removed pins from her fingers. On January 30, 1997, Dr. Parks noted that Sally had massive scarring, particularly over both arms and legs, her face had extensive discoloration and the scars are unlikely to change significantly in the future. Special garments and splints were used to control the development of contracture of scar tissue. He noted, however, that there is absolutely no way known to prevent or to completely control scar tissue. Therefore, Sally's scars are permanent and really can be modified very little in the future. (DP 10)
Webbing and scarring between Sally's fingers limit her from spreading the fingers apart and surgical correction will be necessary to correct this complication
The joint in Sally's right little finger was completely destroyed from the burn. Dr. Parks will need to break the joint and perform arthrodesis or fusion of the right little finger.
Additionally, Sally will need to apply sunscreens due to the sun and light sensitivity of the scar tissue and practice careful hygiene due to the susceptibility to infection.
The scar tissue will never grow hair, never manufacture oil or sweat glands. Therefore, Sally cannot regulate her body temperature and has no reserve or physiology to help control her internal temperature. Dr. Parks notes that Sally is at risk of sunstroke or heat stroke and dehydration. She must avoid any outdoor work due to the temperature and high humidity. This will be difficult since Sally is a painter. Dr. Parks defers a psychological evaluation to Dr. Tarbox, but notes that psychological distress is permanent and will be a major factor for the rest of Sally's life.
E. HEALTH CARE PROVIDERS - SALLY
HOSPITALS
Lakeside Hospital
4444 Farmington Road
Orchard, Texas 5555
(555) 555-5555
PHYSICIANS AND OTHER HEALTH CARE PROVIDERS
S. Reyna
M. Reyes
D. Fornwalt
Easter Regional Medical Services
600 Halberry Blvd.
Red Oak, Texas 55555
(555) 555-5555
Donald H. Parks, M.D. - Plastic surgeon
Mario Kapusta, M.D.
Michael McCallum, M.D. - Emergency room
Edwin L. Parsley, D.O. - Bronchoscopy
Derk W. Krieger, M.D. - Intubation
Elizabeth Hortwell - Blood Bank Transfusion Reaction
Kimberly Henderson, M.D. - Anesthesia
John C. Olson, M.D. - Radiologist
Timothy L. Adams, M.D.
Sandra A. Oldham, M.D. - Radiologist
John Harris, M.D. - Radiologist
Bharat Ravel, M.D. - Radiologist
David L. Zelitt, M.D. - Radiologist
Phan T. Huynh, M.D. - Radiologist
Elyad M. Davidson, M.D. - Anesthesia
Reginald D. Munden, M.D. - Radiologist
Robert F. Lodato, M.D.
Paul Kenny, M.D. - Anesthesia
Christian L. Chong, M.D. - Radiologist
John Baerenstecher, M.D. - Anesthesia
David L. Abramson, M.D. - Anesthesia
Denise Armstrong, D.D.S.
Physical Therapy
Arkansas Regional Center
Elcamino, Arkansas
E. Wayne Looney, D.D.S.
111 W. Orange St.
Elcamino, Arkansas 55555
F. DAMAGES - SALLY WAYMOND
1. Basis of Recovery
Sally Waymond is entitled to recover personal injury damages for her own physical injury; wrongful death damages for the loss of her husband, Lee Leonard Waymond; wrongful death damages for the loss of her son, Timothy Waymond; and her personal injury damages for injury to her daughter, Lee Lynette Waymond.
2. Life Expectancy
Sally Waymond was born on April 30, 1956, and was forty years old at the time of this tragedy. According to the Vital Statistics of the United States, 1993 Life Tables, Sally's life expectancy on August 28, 1996, was forty-one years.
3. Per Diem Evaluation
One of the accepted methods under Texas Law for arguing damages in cases of this type is the per diem argument. For purposes of our present evaluation we will take a per diem approach to the damages. Also, for the sake of simplicity, we will calculate all damages from the date of the tragedy rather than breaking them down as accrued and future.
Sally has a life expectancy of 14,965 days which, calculated on the basis of sixteen waking hours per day, gives her a life expectancy of 239,440 hours.
4. Personal Injury Damages
a. Physical Pain: Sally is entitled to recover for the extreme physical pain which accompanied the burning of the flesh from forty-five (45%) of her body. She also presently endures and will continue to endure in the future the physical pain of exposure to heat, cold, and sunlight. However, the physical pain will subside in the near future after she completes her surgeries and regains some degree of flexibility in her fingers. According to Dr. Parks, most of Sally's pain from her physical injuries will have subsided at the end of five years. Thus, we will ask a jury to award five dollars per hour for sixteen waking hours per day for five years for a total of $146,000 of physical pain arising out of Sally's personal injury.
b. Mental Anguish: We anticipate that the minimum amount which we will ask a jury to award for compensation for the mental anguish which Sally experiences secondary to her burn injuries will be five dollars per hour for the 239,440 hours of Sally's life expectancy. Thus we will ask for a recovery for the mental anguish accompanying Sally's physical injury in the amount of $1,197,200.
c. Physical Disability: Under Texas Law, this is the inability to perform those functions which give us pleasure in life, also known as loss of enjoyment of life. For purposes of this element of damage we retained the services of Dr. Stan V. Smith, President of Corporate Financial Group, Ltd. in Chicago, to calculate the value of the reduction in the value of life of Sally Waymond. Dr. Smith will explain to a jury his calculations of the loss of Sally Waymond's loss of enjoyment of life which totals $2,232,500.
d. Physical Disfigurement: Sally is burned over forty-five percent (45%) of her total body surface area, but she is disfigured over a much larger area because it was necessary to take skin grafts from donor sites which had not been burned. The disfigurement not only causes Sally embarrassment and humiliation, but also results in a severe loss of self esteem and a mental attitude that she will never be loved again because of the horrible scarring on her body. We will ask the jury to award ten dollars per hour for the 239,440 hours for a recovery in the amount of $2,394,400.
e. Loss of Wage Earning Capacity: At this time we are making no claim for Sally's loss of wage earning capacity for the reason that, throughout all of her pain, mental anguish, and disability, Sally continues to climb ladders, paint houses and hang drywall since this tragedy has left her with three children to support -- alone. I much prefer to be able to tell the true story of Sally's courage in supporting her family and doing the best she can with what she has left than to make a claim for damage to wage earning capacity, even though it is obvious that her capacity has been substantially damaged.
f. Medical Expenses: The medical expenses arising out of her hospitalization at Lakeside and her follow-up care totaled $304,279.06. Dr. Parks will testify as to her future medical needs and our life care planner will calculate that her future needs are approximately $100,000, giving Sally a total claim for reimbursement of medical expenses in the amount of $400,000.
5. Wrongful Death of Lee Leonard Waymond
Sally has a substantial claim for the wrongful death of her husband. Lee Waymond was born on August 5, 1952, and he was forty-four years old at the time of his death on August 28, 1996. According to the 1993 United States Life Tables, Lee had a life expectancy of 32.3 years at the time of his death.
Lee and Sally lived together and worked together daily and were inseparable both in business and in their personal lives. Thus, Sally's losses will be calculated on the basis of the 188,632 waking hours which remained in Lee's life expectancy at the time of his untimely death.
a. Mental Anguish: Anyone seeing Sally talk about her relationship with Lee Waymond will immediately understand the incalculable nature of the mental anguish which she is experiencing from the loss of her life's soul-mate. We will ask the jury for an award of mental anguish damages in the amount of five dollars per hour for Lee's life expectancy of 188,632 hours which totals $943,160.
b. Pecuniary Loss: This element of damage in Texas means the loss of the care, maintenance, support, services, advice, counsel, and reasonable contribution of pecuniary value. Dr. Stan Smith will calculate the reasonable value of household services which Sally would have received from Lee throughout his lifetime at $127,858, and the straight pecuniary loss would be in the approximate amount of $106,480. Thus, the bare-bones pecuniary loss claim by Sally for the loss of her husband would be $340,819.
c. Loss of Society and Companionship: Under Texas Law, this element means the loss of the positive benefits flowing from the love, comfort, companionship, and society that Sally would have receive from Lee had he lived. For the thirty-two years of life and love and companionship with Lee which Sally has been denied, we will ask a jury to award ten dollars per hour for Lee's life expectancy for a total of $1,886,320.
d. Funeral and Burial Expenses: Sally Waymond paid the funeral and burial expenses for Lee Leonard Waymond and is entitled to recovery in the amount of $4,753.42.
6. Wrongful Death of Timothy Waymond
Sally is entitled to recover for the wrongful death of her youngest child.
a. Mental Anguish: Sally has been denied the pleasure of being a mother to her youngest child for a total of 239,440 hours. We will ask a jury to award two dollars per hour for the mental anguish which Sally suffers on a daily basis as a result of loss of Timothy for a total of $478,880.
b. Pecuniary Loss: Under Texas Law, this refers to the care, maintenance, support, services, advice, counsel, and reasonable contribution of pecuniary value that Timothy would have made to Sally over her lifetime had he lived. We are making no claim for these damages.
c. Loss of Society and Companionship: Sally enjoyed the positive benefits flowing from the love, comfort, companionship, and society that Timothy gave her on a daily basis. We will ask the jury to award one dollar per hour for the 239,440 hours which Sally has been denied such love, comfort, companionship, and society from Timothy for a total of $239,440.
d. Funeral and Burial Expenses: Sally Waymond paid the funeral and burial expenses for Timothy Waymond and is entitled to recovery in the amount of $4,753.42.
7. Sally's Damages: Lee Lynette's Injury
a. Medical Expenses: Sally is entitled to recover for the reasonable value of medical services rendered to Lee Lynette Waymond from the date of injury to age eighteen. Lee Lynette was born on March 18, 1988. Her eighteenth birthday will be on March 18, 2006.
Dr. Charlene F. Johansen of LifeCare Planning, Inc. in Orchard has calculated the medical expenses which Lee Lynette has incurred in the past and will incur for the remainder of her life in the future. The cost of the total past medical expenses is $407,190. The one-time cost of future medical is $153,020. The annualized cost of recurring medical through March 18, 2006, is $33,060.58. Thus, Sally has a total cost of medical expenses for Lee Lynette through age eighteen in the amount of $593,270.58.
b. Loss of Services: Sally is entitled to recover for the reasonable value of services which Lee Lynette would have rendered had she not been incapacitated. We are making no claim for this element of damage.
G. JURY VERDICT POTENTIAL - SALLY WAYMOND
| 1. Personal Injury Damages | |
|---|---|
| a. Physical pain | $ 146,000 |
| b. Mental anguish | $ 1,197,200 |
| c. Physical disability | $ 2,232,500 |
| d. Physical disfigurement | $ 2,394,400 |
| e. Loss of wage earning capacity | -0- |
| f. Medical expenses | $ 400,000 |
2. Wrongful Death of Lee Leonard Waymond |
|
| a. Mental Anguish | $ 943,160 |
| b. Pecuniary Loss | $ 340,819 |
| c. Loss of Society and Companionship | $ 1,886,320 |
| d. Funeral and Burial Expenses | $ 4,753 |
3. Wrongful Death of Timothy Waymond |
|
| a. Mental Anguish | $ 478,880 |
| b. Pecuniary Loss | -0- |
| c. Loss of Society and Companionship | $ 239,440 |
| d. Funeral and Burial Expenses | $ 4,753 |
4. Personal Injury of Lee Lynette Waymond |
|
| a. Mental anguish | -0- |
| b. Medical expenses | $ 593,270 |
| c. Loss of services | -0- |
H. SETTLEMENT DEMAND - SALLY WAYMOND
Based upon the foregoing review of the liability and damages aspects of this case, we are offering to settle all claims of Sally Waymond arising out of this tragic occurrence for cash or a combination of cash and structured settlement of equal value on the following basis:
| 1. Personal Injury: Self | $ 3,000,000 |
| 2. Wrongful Death: Spouse | $ 1,500,000 |
| 3. Wrongful Death: Son | $ 350,000 |
| 4 Personal Injury: Daughter | $ 300,000 |
| TOTAL: Sally Waymond | $ 5,150,000 |
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