Where a plaintiff with brain injury is found to be essentially unemployable in the open market, the defendant bears the evidential onus of establishing what work the plaintiff can do and what they could earn; failure to discharge that onus supports assessment of future loss of earnings using a conventional multiplier rather than a buffer. The cost of financial management services is compensable where the plaintiff's inability to make adequate financial decisions is caused by the accident, without requiring proof that the plaintiff is at risk of being taken advantage of or prone to inappropriate spending. The identity of a gratuitous carer (whether family member or unrelated guardian) does not affect the assessment of Griffiths v Kerkemeyer damages.
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