On October 24, 2000, our client, thirty-two-year-old Jonna Mays, was a seat-belted driver of a vehicle traveling north on Interstate I-95. Traffic began to slow and Ms. Mays slowed and came to a complete stop. The Defendant, Richard Lucibella, who was using his cell phone at the time, failed to notice the traffic slowing and rear ended Ms. Mays vehicle. The impact was sufficiently forceful to propel Jonna Mays vehicle into the vehicle in front of her. Despite conservative care, Ms. Mays eventually required surgical intervention. Robert A. Zimmerman reached a settlement with Mr. Lucibella’ insurance carrier at mediation and just prior to trial for $1,750,000.00.