Auto policy limits cannot cover all damages. Defendants are willing to tender it. There are many liens from various medical providers, Pharmacy medicines, Medical equipment companies etc. After paying legal fees, left over money under current lien amounts, there will be very little for Plaintiff, not enough for future Med bills. CAN those liens be discounted ?? and if so by how much ? 15% ?, 25 % ? . What is the proper procedure with those providers who may not want to reduce their liens ?? Can the Plaintiff simply instruct legal counsel not to honor them , unless reduced ?? HOW COMMON IS THE DISCOUNTING OF PROVIDER LIENS ?
You state the liens are from medical providers, i.e. PI liens (vs. health ins liens). Providers will reduce liens. the easiest way is probable to do a pro-rata distribution proposal. But the better way is to scrutinize each lien amount versus the reasonable market value of the service. Some providers on liens have very inflated bills and the negotiations will need to start there. This is a true skill that is developed over years of being in practice. Meet with your attorney and devise a game plan and where you want to end up.
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