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DRF-WINTERS-03a-2122-DRF2-TT7

IN THE COUNTY COURT

Claim No.

BETWEEN

MR PERRY WINTERS

Claimant

and

(1) MISS TESSA FREE (2) CATFORD COMPUTERS SALES LIMITED (3) MR ANTHONY ZAPPETTI Defendants

SCHEDULE OF PAST AND FUTURE EXPENSES AND LOSS

Past Losses 1. Clothing damaged beyond repair: Jacket Trousers Shirt Total

£120.00 £ 50.00 £ 30.00 £200.00

2. Spectacles damaged beyond repair

£300.00

3. Prescriptions: Painkillers, 4 at £9.00 each Fluoxetine, an antidepressant, 3 at £9.00 each Total 4. Parking at Lewisham University Hospital 2 full day parking fees 2 x £12 9 parking fees for outpatient appointments, 9 x £4.50 Total

£ 36.00 £ 27.00 £ 63.00 £ 24.00 £ 40.50 £ 64.50

5. Care provided by the Claimant’s wife. On his discharge from hospital on 15 March 2019 the Claimant’s wife provided him with 3 to 4 hours of care and attention each day for 6 weeks to assist him in coping with his injuries. 42 days at 3.5 hours per day = 147 hours The Claimant seeks damages for care and assistance at the relevant commercial rate for nursing care, namely [£ ] per hour, discounted by 25% to take account of the fact that the care was provided by a member of his family. 147 hours x £[ ] per hour x 0.75 £[ ] 6. Loss of income. At the time of the accident the Claimant was employed by the Second Defendant as a Technical Consultant. His gross income was £30,000 per annum, and 1

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DRF-WINTERS-03a-2122-DRF2-TT7

his net income was £22,020.54 per annum (£1,835.05 net per month). As a result of his injuries the Claimant was dismissed from his employment with the Second Defendant in or about March 2020. The Claimant has therefore lost earnings to the date of these proceedings: March 2020 to March 2021: March 2021 to December 2021:

£22,020.54 £16,515.45 £38, 535.99

Future losses 7. Future loss of earnings. By reason of his injuries it is unlikely that the Claimant will be able to return to work for another 4 years. The appropriate multiplier using the Ogden Tables is 4.02 4.02 x £22,020.54 p.a. net

£88,522.57

General damages 8. Handicap on the labour market Further or alternatively, the Claimant will have been out of work for about 5 ½ years as a result of his injuries and will have suffered: (a) Loss of seniority; and (b) Disadvantage in maintaining his level of skill as a Technical Consultant in the Information Technology industry. It is important to be up-to-date in this field in order to maintain an individual’s earning capacity. In the circumstances the Claimant has suffered or will suffer disadvantage on the labour market and seeks: Damages To be assessed

Interest 9. On general damages at 2% pa from the date of service of the claim form. 10. On past losses at half the special account rate from 1 March 2019.

DANIEL MARTIN STATEMENT OF TRUTH etc. Dated etc.

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