| Part #3 | | | | � The plaintiff's earnings (W-2 and tax |
| If you read parts one and two of this series then | | | | records) indicate a smaller earnings history than |
| you are already familiar with some of the | | | | he has claimed. |
| excuses that insurance companies will use to | | | | � The plaintiff was paid in cash for prior |
| deny, delay, or diminish your car accident claim. | | | | employment and can't document his past earnings |
| But there are even more arguments that the | | | | and/or has no tax returns. |
| insurance company will use against you. | | | | � The plaintiff's employer has no official |
| Minimizing the Severity of the Accident | | | | record (i.e., W-2) or other means to substantiate |
| � The property to damage to either or | | | | plaintiff's employment. |
| both vehicles involved was minimal. | | | | Pulling Out all The Stops - Other Common |
| � The plaintiff's vehicle was equipped with | | | | Defenses |
| shock-absorbing bumpers, headrests, seat belts, | | | | � The cost of treatment was excessive |
| which made impact injuries impossible or | | | | and the period during which plaintiff was treated |
| improbable. | | | | was excessive in light of the "standard" or |
| � No other persons involved in accident | | | | "customary" charge for such services. |
| had injuries. | | | | � The injuries should have healed within |
| � The defendant claims he was only | | | | 3-6 mos., so any treatment after that is |
| going 5 mph or less. | | | | excessive or unnecessary. |
| � The damage repair estimate shows | | | | � The plaintiff went to work contrary to |
| only $1,000 of damage to plaintiff's vehicle. | | | | his doctor's advice and thereby aggravated his |
| � The plaintiff's airbags never deployed | | | | injury and/or caused prolonged period of disability |
| so the forces had to be minor. | | | | and/or treatment. |
| � The defendant's airbags never | | | | � The plaintiff's doctor no longer in area |
| deployed so the forces had to be minor. | | | | or otherwise unavailable. |
| Using Your Medical History Against You | | | | � The plaintiff allowed the "Statute of |
| � The plaintiff made errors in recalling his | | | | Limitations" period to expire, thereby forfeiting |
| medical and/or employment history to the | | | | possibility of recovering anything for his claim. |
| insurance company which can be' discovered" by | | | | � The plaintiff was partially at fault and |
| defense during litigation. | | | | should recover less under the rule of |
| � The plaintiff had prior complaints of pain | | | | "Comparative Fault." |
| to the same area of his body before the accident. | | | | � Plaintiff has history of filing lawsuits for |
| � The plaintiff received medical treatment | | | | the purpose of collecting compensation. |
| to the same areas of his body before the | | | | � The plaintiff has a history of mental |
| accident. | | | | illness or emotional problems making him unreliable. |
| � The plaintiff had seen a chiropractor or | | | | There are dozens of other arguments that |
| massage therapist before the accident. | | | | insurance companies commonly use to avoid |
| � The plaintiff had a subsequent injury, | | | | paying a fair and reasonable settlement for your |
| which was the cause of continual problems | | | | injuries. It is the insurance adjustor's job to find as |
| instead of the accident in question. | | | | many of these defenses and arguments as |
| � The plaintiff had no complaint of pain at | | | | possible for the limited purposed of defeating or |
| the physical examination. | | | | minimizing your claim. He will question you very |
| � The plaintiff received mental health | | | | carefully. It all starts when the adjustor wants to |
| counseling or therapy before the accident so | | | | "take your statement". Once you give a |
| perhaps his complaints following the accident are | | | | statement, and provide any information that |
| psycho-somatic. | | | | might support one or more of these "arguments" |
| Minimizing Financial Impact Caused by Your Injuries | | | | it can be very, very difficult to later change the |
| � The plaintiff's doctor did not | | | | insurance company's mind - even if their |
| recommend time off of work yet plaintiff took | | | | argument is totally untrue! Information you give to |
| time off work. | | | | the insurance company early on in the claim can |
| � No doctor has stated that the plaintiff | | | | cause irreparable damage later on. Therefore, be |
| would lose work time in the future. | | | | very careful when speaking to the insurance |
| � The plaintiff had a poor attendance | | | | adjustor! |
| record at work prior to accident. | | | | Seattle personal injury attorney Christopher M. |
| � The plaintiff would have been | | | | Davis is the managing partner of Davis Law |
| terminated, on strike, or laid-off even without | | | | Group. He brings over 15 years of practical yet |
| accident. | | | | innovative experience to personal injury cases. He |
| � The plaintiff had no job at the time of | | | | practices law in Seattle, WA. You can learn more |
| the accident and can't substantiate that he was | | | | about Mr. |
| applying at various places. | | | | |