Plaintiff is a 64-year-old female who was involved in a motor vehicle accident when she was rear-ended while merging on to Route 110. Plaintiff suffered a left shoulder injury requiring surgery and subsequent physical therapy. During negotiations, the defense counsel emphasized the facts that the police report noted there was minimal damage to the plaintiff’s motor vehicle and that the plaintiff suffered from a pre-existing arthritic condition in the shoulder at issue. Prior to trial, the defense offered a top value of $100,000, but after consultation and discussions with the plaintiff about the costs and benefits of a trial, it was mutually agreed that it was prudent to reject this final offer and proceed to trial.