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(For use in conjunction with the Valuation Models for New York Medical and Dental Malpractice Actions under NY50A. It is neither meant to be a legal guide to damage award elements, nor definitive or exhaustive list of award elements and offsets.)

The following is a guide to help the attorney in accumulating data for an Award to be valued. The categories of loss are those into which elements of loss are most often summarized. They are Pain and Suffering, Medical Expenses and Economic or Pecuniary Loss. Element titles may be any descriptive. Losses can be compensated by either periodic or lump sum payments (discrete), and discrete payments can be either one-time or recurring events.

Losses can either be past or future. Past Damages can be thought of in two parts, those expenses immediately incident to the event of loss and continuing expenses that are added to past damages through the passage of time. For purposes of developing a total Award, the attorney should take into consideration the timing of the event of loss, the amount of first payment in future dollars, the sequence of payment, and any annual inflation that occurs after the first year of payment (often referred to as COLA). For purposes of valuing an award for future damages, all payments for loss are considered periodic with initial payment occurring in the immediate future. (In fact, initial payments are first payable on the date of the verdict unless otherwise agreed by the parties or specified in the verdict.)

Case Information

a.) Case Caption: ________________________________________________

b.) County of Filing: _______________________________________________

c.) Docket: _____________________________________________________

d.) Plaintiff: __________________________________________________

e.) DOB: ___________ Sex: _________ Life Expectancy:_________________

f.) Decedent: _____________________ Date of Death:_______________

g.) DOB: ___________ Sex: _________ Life Expect. at Death Time:__________

h.) Date of Event: ___________ Date from which losses began: ___________

i.) 50A or Amended 50A: _________50A Wrongful Death: ___________

(In wrongful death actions under 50A as amended, future damages are to be paid as a lump sum without further reference to Section 5031. Section 5031 provides for discounting of future damages, deduction of litigation expenses and attorney fees and setoff of comparative negligence and settlements. Prior to amended 50A, the Awards were to be reported out without reference to the periods over which they were to be paid (Lump Sum). No mention is made of Collateral Source Offsets as set up under Sec. 4545, but, since there is no future expense against which collateral source is to be applied, there may be no offset.)

Litigation Expenses: _______________

Past Damages: ______________

1.) Pain and Suffering

a.) Damages Incident to Event of Loss-Amount: _____________

b.) Period for Future Payments: ____________ (Maximum 10 years- 8 years under Amended 50A)

c.) Amount: _______________

2.) Lost or Impaired Earnings

a.) Description: ____________________________________________

Periodic (Simple)

i.) Period for Payment _______Years, _____Months

ii.) Payment Sequence (Monthly etc.)_______________

iii.) First Payment Date_____________

iv.) Current Cost_____________

vi.) Annual Inflation (Cola) after first Payment

Periodic (Complex)

i.) Period for Payment _______Years, _____Months

ii.) Payment Sequence (Monthly etc.)_______________

iii.) First Payment Date_____________

iv.) Current Cost (Base) _____________

v.) Annual Inflation rate to be Applied to reach 1st. Payment______________

vi.) Annual Inflation (Cola) Age 21 to 30   ______________

vii.) Annual Inflation (Cola) Age 31 to 40  ______________

viii.) Annual Inflation (Cola) Age 41 to 50 ______________

ix.) Annual Inflation (Cola) Age 51+          ______________

x.) Commission Current ___________   expected % of Base ____________

xi.) Incentive Bonus         ___________   expected % of Base ____________

xii.) Other Current           ____________  expected % of Base ____________

xiii.) Other Current          ____________  expected % of Base ____________

xiv.) Sustaining Expenses __________  expected % of Gross____________

xv.) Current Total Taxes Paid_______________

Taxes Associated with Lost Earnings (specified in Sec. 4546 for Actions under 50A.)

Statutory Rates: __Simple __ Pooled (Lower Level Taxes deducted before higher level taxes applied

Federal Rate______ applies to ______% of Earnings

State Rate_______   applies to ______% of Earnings

Local Rate_______   applies to ______% of Earnings

or Taxes Paid

                Year 1              Year 2            Year 3

Earnings  ________       ________      ________

Fed. Tax  ________        ________     ________

State Tax ________        ________     ________

Local Tax ________        ________     ________

3.) Loss of Services. (These are services that are reasonably certain to be incurred and necessitated by plaintiff's injuries or loss of decedent. Under Sec. 4111, 50A Awards are to be returned by the jury in total without reference to period over which to be paid.)

a.) Description: ____________________________________________

b.) Periodic

i.) Period for Payment _______Years, _____Months

ii.) Payment Sequence (Monthly etc.)_______________

iii.) First Payment Date_____________

iv.) Current Cost_____________

v.) Annual Inflation rate to be Applied to reach 1st. Payment______________

vi.) Annual Inflation (Cola) after first Payment _________%

4.) Loss of Consortium (Generally, New York restricts payments to items of pecuniary loss, though there are references to Loss of Consortium in case law and in the statutes. To the extent that a claim can be made, it should be joined, where possible, with the underlying action. Under Sec. 4111, 50A Awards are to be returned by the jury in total without reference to period over which to be paid.)

a.) Description: ____________________________________________

b.) Periodic

i.) Period for Payment _______Years, _____Months

ii.) Payment Sequence (Monthly etc.)_______________

iii.) First Payment Date_____________

iv.) Current Cost_____________

v.) Annual Inflation rate to be Applied to reach 1st. Payment______________

vi.) Annual Inflation (Cola) after first Payment _________%

5.) Other Economic Loss

a.) Description: ____________________________________________

b.) Damages incident to Event of Loss-Amount: _____________

c.) Periodic

i.) Period for Payment _______Years, _____Months

ii.) Payment Sequence (Monthly etc.)_______________

iii.) First Payment Date_____________

iv.) Current Cost_____________

v.) Annual Inflation rate to be Applied to reach 1st. Payment______________

vi.) Annual Inflation (Cola) after first Payment _________%

d.) Discrete (Lump Sum Payments)

i.) Number of Events ____________

ii.) Payment Sequence (every 2, 3 or 4 years etc) _______________

iii.) First Payment Date_____________

iv.) Current Cost_____________

v.) Annual Inflation rate to be Applied to reach 1st. Payment______________

vi.) Annual Inflation (Cola) after first Payment ________%

6.) Medical Expenses

a.) Description:____________________________________________

b.) Damages incident to Event of Loss-Amount: _____________

c.) Periodic

i.) Period for Payment _______Years, _____Months

ii.) Payment Sequence (Monthly etc.)_______________

iii.) First Payment Date_____________

iv.) Current Cost_____________

v.) Annual Inflation rate to be Applied to reach 1st. Payment______________

vi.) Annual Inflation (Cola) after first Payment

d.) Discrete (Lump Sum Payments)

i.) Number of Events ____________

ii.) Payment Sequence (every 2, 3 or 4 years etc) _______________

iii.) First Payment Date_____________

iv.) Current Cost_____________

v.) Annual Inflation rate to be Applied to reach 1st. Payment______________

vi.) Annual Inflation (Cola) after first Payment

7.) Collateral Source Payments (Offsets). These are obligations to pay occasioned by the loss, e.g. Social Security Survivor Benefits. There must a reasonable certainty of payment (subject only to the continued payment of premium and such other financial obligations as occasioned by the agreement), and the source must not be entitled to a statutory lien. Collateral Source obligations may also apply to care, custodial care and rehabilitative care, though it is difficult to envision any where the only condition to delivery of care is continued premium payment.

i.) Description _________________________________________

ii.) Period for Payment _______Years, _____Months

iii.) Payment Sequence (Monthly etc.)_______________

iii.) First Payment Date_____________

iv.) Current Payment Amount_____________

v.) COLA Applicable _________%

vi.) Cost of Maintenance (last two years)___________

vii.) Ongoing Cost to Maintain______________

viii.) Inflation on Ongoing Cost______________

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Last modified: January 9, 2008