Lost Wages and Earning Capacity Worksheet From Pay Records
Computes past lost wages from pay records, employer letters, tax documents and disability notes with every step of arithmetic shown, reconciles the documents against each other, and separates future earning capacity into a list of what the economist or vocational expert must supply.
The Prompt
Variables (8)
| Variable | Description | Example |
|---|---|---|
| {{client_name}} | Client Name | Maria Gonzalez |
| {{occupation}} | Occupation | Registered nurse, hourly, full time |
| {{incident_date}} | Incident Date | 2026-06-14 |
| {{work_status}} | Current Work Status | Returned with restrictions or reduced hours |
| {{wage_rules}} | Governing Rules on Wage Loss | Paste the pattern jury instruction or statute text on lost earnings, collateral source and present value, or write UNKNOWN |
| {{pay_records}} | Pay Records and Tax Documents | Pay stubs for the 26 pay periods before the incident and all periods since; 2024 and 2025 W-2s; 2025 Form 1040 with schedules. |
| {{employer_letters}} | Employer Letters and Wage Verification | HR letter dated 2026-08-20: "Ms. Gonzalez was absent from 6/15/2026 through 7/26/2026 and returned on a 24-hour weekly schedule. Her base rate is..." |
| {{disability_notes}} | Disability Notes and Work Restrictions | Work status note dated 2026-06-23: "Off work until re-evaluation." Note dated 2026-07-24: "May return to light duty, no lifting over 10 lbs, 6-hour shifts." |
Expected Output
A worksheet with: conflicts between sources, the earnings base table with sources, a time-off calendar split into segments supported and unsupported by a medical note, a line-by-line past loss computation ending in two separate totals (supported and unsupported by a medical note, never one combined headline figure, and with open-ended periods reported but not priced), amounts received from other sources listed separately, a reconciliation table across pay stubs, employer letters, W-2s and returns, documented facts on future earning capacity with the inputs required from the economist and the vocational expert, missing information (including the note needed for each unsupported segment), unsupported statements declined, declined requests, and a closing Verification list that ends the output.
Usage Notes
Use when preparing the wage-loss section of a demand, answering damages discovery, or briefing an economist. Attach pay stubs covering a full pre-incident period, the employer wage verification, tax documents and every work-status note. Paste your jurisdiction's rule on gross versus net wages and collateral sources: the prompt will not apply one on its own. Failure modes to watch: days of absence with no medical note behind them folded into the headline figure, an employer letter whose own arithmetic is wrong, and overtime counted without a documented pre-incident pattern. Use the supported subtotal unless you have the missing note, and recompute the total yourself before it is used. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Legal Sources Referenced
- Jones & Laughlin Steel Corp. v. Pfeifer, 462 U.S. 523 (1983) (LHWCA: award for lost future earnings is discounted to present value; choice of discount rate)
- Norfolk & Western Ry. Co. v. Liepelt, 444 U.S. 490 (1980) (FELA wrongful death: income tax on future earnings is relevant to the lost-earnings computation)
- Fed. R. Civ. P. 26(a)(1)(A)(iii) (initial disclosure of a computation of each category of damages and the supporting documents)
Originally featured in: AI for Personal Injury Lawyers: Prompts for Demand Letters, Medical Summaries & Depositions
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* These prompts are drafting and analysis aids for licensed attorneys. They are not legal advice and do not replace professional judgment. AI output can contain errors, including invented citations and incorrect deadlines: verify every fact, figure, authority and deadline against primary sources before relying on it. Rules vary by jurisdiction, and you remain responsible for the final work product.