Section 37 Charts

• Library: Damages 2012

To emphasize the impairment of the plaintiff’s capacity to perform household chores, counsel should prepare two charts:

1. Those chores an injured plaintiff can no longer do

2. Those chores the plaintiff can do now, but only with great difficulty

The following are examples of charts that might be prepared to explain lost household contributions of a farm wife who was rendered a paraplegic:

Things Cannot Do

· Can fruits and vegetables

· Lead horses while husband plows garden

· Take care of cattle and horses—feed, lead to water

· Pick up rocks on farm

· Help put up hay—buck bales, drive truck

· Thorough house cleaning

· Move heavy furniture

· Wash all windows

· Change light bulbs on ceiling fixtures

· Drive

·...