“The facts and circumstances listed below tend to establish the nature and extent of a plaintiff’s pain and the plaintiff’s pain threshold: Plaintiff’s physical condition before injury; Injuries to plaintiff; Hospitalization and treatment of injuries; Lingering pain after discharge from hospital; Description of pain; Mental and emotional stress resulting from pain; Effect of pain on ability to work; Effect of pain on recreational pursuits; Sexual and marital problems; Family problems; Evaluation at pain clinic [medical history, physical examination, CAT scan, myelogram]; Past and future treatment received at pain clinic [physical therapy, occupational therapy, behavior therapy, psychological counseling, analgesics, antidepressants]; Improved ability to cope with pain; Diagnosis of chronic pain; Absence of malingering; Plaintiff’s low pain threshold.”
[Stein on Personal Injury Damages [certain citations omitted]]
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