The client sustained a shoulder surgery when an elderly unlicensed driver plowed into her vehicle in front of Macy’s. After two surgeries, the case was ready to settle, but during protracted negotiations, the insurance carrier only offered $75,000, stating that the client’s job involved heavy lifting which contributed to her condition. After a lawsuit was filed, they offered to mediate, and then withdrew from mediation stating they weren’t going to offer any more money so why bother. While the lawsuit was pending, the client did indeed re-injure herself at work, causing need for a third surgery, and further entrenching the insurance company in its position. However, during depositions, the attorneys were able to show that the client’s doctors supported her position that the accident caused the need for the first two surgeries and the day before trial was due to begin, the defendant more than doubled its offer and the case settled for $160,000.00.