In order to avoid colliding with the cargo I veered left and it was at that time that the defendant hit my vehicle. ANSWER: As a direct result of the first defendant’s negligence I was thrown to the ground with great force and sustained head, neck, back and other bodily injuries. Facial bones were broken in nine places and I suffered compound comminuted fracture of the right tibia and a cerebral concussion. The resulting treatment at the Paxton Medical Center where broken facial bones and jaw were negligently wired in place only complicated matters and my face is now significantly disfigured and the prognosis for a full recovery is slim. c. The photographs of the accident scene were taken at the scene at the date and time of the accident, May 8, 2006.
Photographs of the juries were taken at that time by police officers and by a private photographer. Photographs of my injuries were also taken at the Chicago Metropolitan Memorial Hospital on May 10, 2006 by my private photographer. a. An accident reconstruction expert will testify that the first defendant was driving at an excessive speed and in a manner dangerous to other motorists. A cosmetic surgeon will also testify to the extent of facial damages and his prognosis for repair. Other experts will include the physicians treating me following my release from Paxton Medical Center. b. The accident reconstruction expert will testify that the defendant’s negligence caused the accident and the medical experts will describe my injuries and the medical errors complicating them as well as the nature of my current and future treatment. c. The accident reconstruction expert is generally of the opinion that the size of the Nissan truck driven by the first defendant together with the weight of its cargo required that the truck be navigated cautiously and at a reasonable speed.
The lack of caution in the circumstances of the trucks size and weight was a direct cause of the accident. The medical
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