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Martinez v. Smith — MVA
Strong liability · Documented injuries · Clear causation
| Jun 14 | ER visit — C5-C6 herniation diagnosed | Valley Medical |
| Jun 28 | MRI confirms disc herniation | Desert Imaging |
| Jul 10 | Pain mgmt — epidural injection #1 | Dr. Patel |
| Sep 18 | Surgical consult — ACDF recommended | Dr. Hernandez |
| Valley Medical ER | $18,450 | 4 line items |
| Desert Imaging | $3,200 | 2 line items |
| Dr. Patel Pain Mgmt | $12,100 | 8 line items |
| Desert Physical Therapy | $8,535 | 12 line items |
| Dr. Hernandez Consult | $5,000 | 1 line item |
Full line-item breakdown exportable as Excel
| Medicare Part B | $12,400 | Confirmed — NOI required |
| Desert Imaging | $3,200 | Negotiable |
| Valley Med ER | $7,685 | Negotiable |
| Total exposure | $23,285 |
MISSING: Initial ambulance/EMS report — needed to establish mechanism of injury at scene. Request from County EMS.
INCOMPLETE: Physical therapy discharge summary from Desert PT (last visit Aug 30) — request from provider.
21 of 22 scheduled appointments attended. 1 missed appointment (Jul 25) documented as work conflict, rescheduled within 3 days. Treatment plan followed as prescribed. Rating: EXCELLENT.
Mild degenerative disc disease (L4-L5, 2019 MRI) — likely defense argument, but anatomically distinct from current C5-C6 injury. Risk: LOW — different spinal level.
Hypertension (managed, on medication since 2018) — unrelated to current injury. Risk: MINIMAL.
Orthopedic Surgery — causation opinion re: C5-C6 herniation and need for ACDF. Strong fit for mechanism-to-injury testimony.
Pain Management — document chronic pain trajectory and future treatment needs for damages calculation.
Vocational Rehabilitation — if client reports work limitations, supports economic damages claim.
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