Plaintiff Summary: Christopher Shane Mason

Meeting Overview

  • Participants: Bill and an unidentified person discussing the deposition of plaintiff Christopher Shane Mason.

  • Purpose: Update and align on the deposition findings related to the case involving plaintiff Mason.

Plaintiff Summary: Christopher Shane Mason

  • Case type: A unique case involving a cross plaintiff.

  • Deposition focus: Mason is the first plaintiff being discussed.

    • Professional Appearance: Presented in a suit, seen as professional with good jury appeal.

    • Personal Background:

    • Married with two daughters (one living at home, the other in California).

    • Self-employed with a claim of wage loss related to business rather than direct wage loss.

Wage Loss Claim

  • Description: Mason claims a business loss connected to the accident instead of a straightforward wage loss.

  • Additional Details:

    • Hired two employees post-accident, yet details about their roles are unclear.

    • Ongoing discovery requests to obtain subpoenas for business records related to these claims.

Medical History

  • General health:

    • No regular doctor (PCP currently); previously had one in South Florida.

    • Health insurance lapsed recently.

    • Prior chiropractic care characterized as maintenance, could not recall the chiropractor's name but indicated visits in the year before the incident.

  • Accidental Background:

    • Admitted to no prior motor vehicle accidents, substance use or disorders.

    • Denied previous pain management or surgical treatments addressing shoulder, neck, or lower back concerns, aside from chiropractic adjustments.

Accident Details

  • Description of accident:

    • Mason driving a Tundra, entering an intersection with a green light.

    • Observed vehicles stopped at a red light; stated that the defendant (insured) pulled out in front of him.

    • Action taken: Made a split-second decision to maneuver avoid collision, leading to being rear-ended by a co-defendant.

  • Liability complexity due to various parties involved in the accident.

Injuries Sustained

  • Initial sensations: Reported pressure in the hips at the accident scene without pain.

  • Medical treatment timeline:

    • First treatment was chiropractor at Coastal Integrative Health which he later discontinued.

    • Subsequent visits to a neurosurgeon at AdventHealth were noted; recommended to follow a home exercise plan.

    • Considering to return to Zion Medical for further treatment (pain management).

Daily Activity Limitations

  • Activities affected:

    • No prolonged sitting or standing.

    • Previously enjoyed jogging and golfing; reported difficulty with ordinary activities like washing the car and tying shoes.

  • Recent Activities: Visited California to see his daughter and did not participate in rides at Disney World.

  • Social Media Presence: Reports having only a business account with an absence of personal accounts.

Next Steps for the Case

  • Required Actions:

    • Further discovery related to the wage loss and subpoenas to be issued post-deposition.

    • Plan to schedule a Comprehensive Medical Examination (CME).

    • Follow-up on discovery and subpoenas for Mason's business records.

    • Consideration of a medical reread order for previous imaging findings.

    • Confirmation of no trial date available at this moment.

Medical Findings

  • Owner of several significant medical issues observed:

    • Shoulder: MRI indicated edema and a partial tear.

    • Cervical Spine: ~C4-5 herniation with annular fissure; edema noted in multiple levels including C5-6 and lumbar regions (L2-3, L3-4, L4-5, L5-S1).

    • Suggested reread of films for accurate interpretation to support upcoming litigation needs.

Financial Overview

  • Medical bills totaled approximately $19,000 currently (specific figures discussed included $38,032.09 at Coastal Integrative and other locations).

  • Negotiation history: Last offer was recorded at $32,000 with no response from the opposing counsel.

  • Planned action: File a Plaintiff Fact Sheet (PFS) to prompt a response from the plaintiff’s side.

Cross Plaintiff Information

  • Context of case dynamics:

    • Johnson vs. Klimowitz as related parties with separate but interlinked claims in the same lawsuit.

    • Deposition for Johnson planned, need for mediation to negotiate resolutions for both claims.

Conclusion

  • Meeting summary confirmed necessary follow-ups on treatment records, setting mediation, and determination of life-altering impairments developed from injury. Discussion ended with plans for further communications regarding next steps, including the management of additional medical findings and compliance with the court's discovery processes.