Read the scenario and medical information below. Based on the information provided, draft a damages summary and records document that would be included in a trial notebook.

Facts:

They had spent the day shopping. Charles Chumley, 60 years old, was driving while Julia, his wife of 35 years, was in the passenger seat beside him. They had visited a larger town about 30 miles away and had spent the day at the mall. Now they were heading home. They had lived in the town of Cling for almost 20 years. Charles had a job nearby as a shift supervisor at a plant that made wooden chairs and tables. Julia had worked at city hall as a secretary until she retired last year. For the past few months, they had enjoyed taking little shopping trips together on the weekends. Charles was looking forward to his retirement. He used to joke to her that they would get a camper and drive all over the country. Julia didn't like driving, especially long trips, but she would play along with him. Around 4:30 that Saturday afternoon, they reached the outskirts of town and turned down their street. Morgan Street hadn't changed much in 20 years. Just short of their house, a railroad track crossed Morgan Street. There wasn't a stop sign or a mechanical gate, just one "cross-buck" sign that read "Rail Road Crossing." Charles had driven across that track at least twice a day, five days a week for 20 years. The thick evergreen trees that grew near the intersection made it hard for him to see down the track. What happened next has been pieced together from the facts. There is no dispute that when the Chumley car crossed the tracks, it was struck broadside by a 32-ton train, owned by National Railroad Company. The impact sounded like a small bomb going off, as some neighborhood people said later. The car was impaled on the front of the locomotive engine and pushed about 100 yards down the track, before the car finally rolled off the front of the railroad engine and slid into a ditch. Charles was severely injured, and Julia was killed instantly. Fortunately for Charles, a fire station was only two blocks away and it was equipped with an ambulance. Fire and rescue got to the scene in less than three minutes. They cut Charles out of the car, but there wasn't anything they could do for Julia. Charles was airlifted from the scene to a nearby city and spent several months in the hospital there. Although he almost died in intensive care, he managed to pull through. He has no memory of the collision. He walks with a cane now. He has severe, permanent injuries that prevent him from ever returning to work or even driving a car again. His wife is dead. His life has been devastated. Mr. Chumley's health was excellent before the crash, with only occasional ulcer trouble and some infrequent thyroid problems. In the five years before the crash, he had missed only three days from work. However, after the collision, his health took a drastic turn for the worse. The injuries he received have had a dramatic impact on his life. In addition to his physical injuries, there are also out-of-pocket expenses and the pain and suffering he has endured. Mr. Chumley's injuries included a closed head injury, fractured left tibia, internal hemorrhaging, hemopneumothorax (blood-filled, collapsed lung), and severe abdominal trauma. In addition, he had five broken ribs and a left hip fracture. Mr. Chumley has had extensive surgery on several occasions and suffered from severe infections. For three months following the collision, Mr. Chumley languished in a coma, his breathing controlled by a ventilator. When he finally revived, doctors noted that Mr. Chumley

Medical Bill Totals for Charles Chumley

Mission Hospital $219,380.01

Mission Clinic $2,677.94

EMS $65.50

Carter Surgical Associates $12,935.00

Barnes Radiology $4,561.00

Barnes Rehabilitation Hospital $83,494.41

Barnes Bone and Joint Clinic $6,151.20

Medical Internist's Association $23,118.27 Doctor's Family Care $760.00 Barnes Diabetes Medical Assoc. $12,398.45 Joseph Frazier, M.D. $5,692.02

Medical Information about Charles Chumley:

BARNES REHABILITATION HOSPITAL PLACID CITY, PL 10000 HISTORY AND EXAMINATION NOTES PATIENT NAME: Chumley, Charles ADMISSION DATE: December 2, last year HOSPITAL NUMBER: 003-03-9087 HOSPITAL UNIT: HEAD TRAUMA The medical records have been reviewed and the admitting Physician Assistant and Dr. Frazier have examined the patient. Date of birth: 5-5-61 INFORMATION PROVIDED BY: Patient, patient's two sons, records from Mission Hospital. PROFILE: This is the first admission to BRH of this white, right-handed male, who previously lived with his wife, Julia, in Cling, Placid. Patient's wife was killed in the accident in which he received his injuries. The patient has a high school education. He worked at Knight Manufacturing Co. for 25+ years. His hobbies included playing golf and walking. He also enjoys watching professional football. CHIEF COMPLAINT: "I was in an accident with a train and was in a coma for a couple of months." HISTORY OF PRESENT ILLNESS: The patient was involved in an automobile-train accident in August of this year. The patient suffered multiple traumas. He was initially admitted to Cling Hospital immediately after the accident, but was then transferred to Mission Memorial. The patient's injuries included intraperitoneal hemorrhage, severely displaced left tibial plateau fracture, left hemo-pneumothorax, left elbow lacerations and a closed head injury. The patient underwent an ORIF for his left tibial plateau fracture as well as exploratory laparotomy with a splenectomy. The patient also had five broken ribs and a left hip fracture. The patient had a tracheostomy placed on August 30, of last year. The patient's hospital course was complicated by resistant organisms in the sputum causing acute and chronic bronchitis. The Infectious Disease Consultants for this followed him. The patient was also followed by Dr. Wellby for his pulmonary difficulties. The patient's hospital course was also complicated by the inability to pass a G-tube secondary to the patient's significant abdominal trauma. The patient has fistula development with infections of the fistula. The patient, therefore, required central hyperalimentation. The patient has been receiving this via triple lumen catheter. Catheter was placed on October 14. The patient has tolerated this well and, in fact, has been able to eat some by mouth, having had a video fluoroscopy done on November 5. PAST MEDICAL HISTORY: The patient has suffered the usual childhood diseases without sequelae. Medically, the patient was diagnosed as having hypertension and was started on medication approximately one month prior to his injury. Trauma history none, confirmed by both sons. HABITS: Patient quit smoking about ten years ago. Previous to that, he smoked about 1- packs per day for 30+ years. The patient does not consume alcoholic beverages. He usually drinks sweet tea, diet soft drinks, and water. ALLERGIES: NONE.