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Excerpt from Millott v. Reinhard

Housekeeping

[264] The calculation or estimation of housekeeping damages requires the Court to ascertain the value of the housekeeping services Millott used to perform. This is done by quantifying the number of hours spent annually by the deceased on housekeeping matters, and then assigning a dollar value to those activities. The resulting annual figures are then converted to a lump sum, present value figure, using the same rationale and methodology as discussed earlier in relation to income. The Plaintiffs presented Karen Kirker as an expert in evaluating the loss of household services. Her report was entered as evidence, and she testified at trial.

[265] Before addressing the Millott family's particular factual situation, I must first address some preliminary legal issues surrounding the assessment of housekeeping damages.