“The following facts and circumstances, among others, tend to establish reliable indicia of pain and suffering: Previous good health of plaintiff; Absence of previous health restrictions; Numerous visits to physician; Disability to perform activities normal for an individual of plaintiff’s age and circumstance; Problems in adjusting to injury; Descriptions of pain; Marital and sexual problems; Necessity for surgery; Permanent disfigurement; Permanency of injury; Certainty of pain and suffering; Absence of malingering and lack of need for financial gain; Conversion pain.”
[Stein on Personal Injury Damages [certain citations omitted]]
