Section 11 Lay Witnesses

• Library: Damages 2012

Friends, neighbors, fellow workers, employers, ministers, and close relatives are excellent sources of showing the mental anguish and pain an individual has endured because of an accident. They can provide numerous and practical illustrations of the injured plaintiff experiencing pain and suffering on a day-to-day basis. They can also verify that the plaintiff was a healthy, functioning individual before the injury. See Partello v. Mo. Pac. Ry. Co., 117 S.W. 1138, 1140–41 (Mo. 1909). The following is a sample...