| Medical specials |
Anchor for both negotiation posture and general damages estimation. |
Total billed and total paid, plus future care estimate if applicable. |
| Other specials |
Often overlooked and can meaningfully move the floor. |
Lost wages, loss of earning capacity, mileage, property damage, out-of-pocket. |
| Injury severity |
Drives multiplier selection and jury perception. |
Diagnosis, imaging, surgeries, permanency, scarring, disability ratings. |
| Treatment timeline |
Gaps can reduce perceived seriousness and affect causation arguments. |
First treatment date, last treatment date, gaps greater than 30 days. |
| Liability and comparative fault |
Can compress the entire range and change demand strategy. |
Admissions, citations, witness statements, reconstruction, plaintiff conduct. |
| Insurance limits and collectability |
Practical ceiling for many pre-suit settlements. |
Known limits, umbrella coverage, employer policies, assets. |
| Venue and jury patterns |
Two similar injuries can value very differently by county and judge. |
County, judge, comparable verdicts and settlements by injury type. |