Damages Calculation - Emmanuel Kepas.xls

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Damages Calculation - Emmanuel Kepas.xls Powered By Docstoc
					                                            Manny Kepas Damage Calculations
This spreadsheet assumes a 5 day work week. If a six day work week, change values in H Columns from 4 to 5
Today's Date                     8/9/2012                    Days Since Action                                    Today's Date                                           8/9/2012               Days Since M. R. Hire
Action Date                    2/16/2006                                2366                                      Most Recent Job Hire Date                              8/1/2007                         1835
Term. Date                     9/21/2006            217.00          2149.00
Back Pay                                                                                           Work Weeks and Days
                                            Hours                                                  Since Action                        Back Pay
                             Hourly Rate    Per Day          Daily Rate         Weekly Rate Weeks                 Days                 Owing
                 Standard         $39.33                8           $314.64        $1,573.20               338                     0       $531,741.60
                 Overtime*                                              $0.00              $0.00           338                     0                $0.00
                 Bonuses**        $50.00                8           $400.00        $2,000.00               338                     0       $676,000.00


                                                                                                                  Total Back Pay                                   $1,207,741.60
* Total overtime hours should be calculated by averaging the number of overtime hours for each year of work
** Total includes all compensation above salary figured by average of 2004 ($108,788) and 2005 ($99,183) or ($103,985.50)


Benefits                                                     Increased          Increased                                              Total cost            (This is unique to Manny's case)
                                                             Monthly            Weekly                                                 of insurance
                                                             Cost               Cost                                                   or amount
                                                             or lost            or lost                                                of lost
                             Employee       Cobra            monthly            Weekly             Months and Weeks                    insurance
                             Contribution Payment            benefit            benefit**          Since Termination                   benefit
Health Insurance                    $0.00       $177.67             $177.67               $41.32             7                     1             $1,285.01
Dental Insurance                   $0.00        $30.33                 $30.33              $7.05             7                     1              $219.36
Life Insurance                                                         $68.32             $15.89             7                     1              $494.13
Disability                                                              $0.00              $0.00             7                     1                $0.00


                                                                                                                  Total Benefits                                       $1,998.50
** Weekly benefit is calculated by dividing monthly cost by 4.3 (average number of weeks in a month)



Benefits                                                 Increased          Increased                                             Total cost
                                                         Monthly            Weekly                                                of insurance
                                                         Cost               Cost                                                  or amount
                                                         or lost            or lost                                               of lost
                            Employee       Cobra         monthly            Weekly             Months and Weeks                   insurance
                            Contribution Payment         benefit            benefit**          Since Termination                  benefit
Health Insurance                 $177.67       $889.80          $712.13            $165.61              69                    1         $49,302.58
Dental Insurance                 $30.33       $121.03              $90.70             $21.09            69                    1             $6,279.39
Life Insurance                                                     $99.19             $23.07            69                    1             $6,867.18
Disability                                                          $0.00              $0.00            69                    1                $0.00


                                                                                                             Total Benefits                               $62,449.15


** Weekly benefit is calculated by dividing monthly cost by 4.3 (average number of weeks in a month)


                                                                                                             Total Back Pay
                                                                                                             and Lost Benefits                          $1,272,189.25



Wages Made and Payments Received


Wages received from new employer                                                                                                            $170,689
Unemployment Benefits



                                                                            Total Wages and Benefits minus mitigation amounts                           $1,101,499.89   ##########
Other Actual Damages (Such as Medical Costs)


Impairment to Lifetime Earning Capacity                                                                               $2,655,513.00
Bonus Reduction in Demotion from Grade 26 to 25                                                                             $7,760.85
Layne M. Garrett (AuD. FAAA)                                                                                                $4,603.80


Mark Treuhaft (LCSW Psychotherapist)                                                                                           $400.00
Anticipated (Twice a month for a year)                                                                                      $1,920.00
Chad Daniels (Audiologist)                                                                                                      $26.10
Eric Caten (Psychiatrist)                                                                                                       $30.00
Dr. Tagge (IME)                                                                                                                 $44.40
Patrick McDermott (Primary Care Physician, Internal Medicine)                                                                  $356.80
Anticipated (Monthly visits for a year)                                                                                        $180.00
Keith Finlayson (ENT)                                                                                                           109.40     $15,431.35


                                                                                                    Total Actual Damages                 $3,772,444.24



Front Pay                                    Hours                                    Work Weeks Front Pay
                             Hourly Rate     Per Day   Daily Rate       Weekly Rate Claimed         Claimed
               Standard                                         $0.00         $0.00            78             $0.00 Value of
               Overtime*                                        $0.00         $0.00            78             $0.00 Benefits
               Bonuses**                                        $0.00         $0.00            78             $0.00        $16,362.22
Current Wage                         $0.00                      $0.00         $0.00            78             $0.00


                                                                                      Total Front Pay                                           $0.00
* Total overtime hours should be calculated by averaging the number of overtime hours for each year of work




                                                                                      Total Actual Damages and Front Pay                 $3,772,444.24
Compensatory Damages (Three Times Total Actual Damages and Front Pay)                                  $11,317,332.73                           600,000

                                                  Total Actual Damages, Front Pay, and Compensatory Damages               $15,089,776.97


Total Attorney Fees and Costs to Date                                                                    $125,000.00                       $4,497,444.24

                                                                                       TOTAL DAMAGES                    $15,214,776.97
Days Since M. R. Hire

				
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