On February 18, 2019, while still in her driveway, our client noticed an oil truck making a delivery to a home at the end of her street, backing toward its dead-end location. As she backed her own car out of her driveway, she was under the impression that the delivering truck would await her exit to the street. However, the oil truck continued to travel in reverse but had no functioning back up alarm to alert her that he was still backing into the dead-end. After the two vehicles impacted, the police responded to the scene, and noted the inoperable alarm, which an oil delivery company supervisor acknowledged at the scene. The truck driver was barred from testifying at trial, by the court, for non-appearance at depositions. Our client developed a right hip labral tear which required debridement and an anterior-superior labral repair. As a result of lower back injuries and positive MRI findings, and failed epidural spinal injections, she remains a surgical candidate for a right L4-L5 lumbar discectomy and foraminotomy, and a right L5-S1 hemilaminotomy and discectomy. Due to a partial tear of a tendon in the right shoulder with arthritic changes and an AC joint impingement, she is a surgical candidate for a right shoulder subacromial decompression, and rotator cuff debridement/ repair, as cortisone injections have failed. The defense had no medical expert to dispute our client’s objective injuries. Our client missed 2 months from employment from 2 jobs, following the accident, and received NJ State Disability. However, she lost an additional $8,000, on top of any State benefits.