Read the scenario below. Based on the facts, draft a litigation chart, including the allegations, witness, testimony summary, and physical evidence.

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 3that 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