Our client was a 41 year old mother of two who worked as an esthetician. She was walking across a street in a pedestrian crosswalk when a driver ran over her. Her right clavicle was dislocated with both ends rotated grossly out of position. This left her with permanent pain and instability of her right shoulder which failed to improve even after surgery. She also developed significant post-traumatic stress that left her anxious and very easily overwhelmed. The combination of her impairments prevented her from working. We sued the driver and brought an application to our own client’s insurance company to have her declared to be catastrophically impaired (to allow her to access increased benefits). The defendant driver testified that our client stepped out in front of his vehicle without warning but we were able to prove this evidence unreliable through cross-examination on examination for discovery and with an engineering opinion. We were able to convince our client’s insurance company that the combination of her impairments left her catastrophically impaired. We ultimately settled the lawsuit against the driver and the accident benefits claim for a total of $1,875,000. The settlement removed our client’s financial stresses and allowed her to concentrate on rehabilitation.