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Last year the Court of Appeals held in Toledo v. Iglesia Ni Christo1 that plaintiffs can recover pre-verdict interest on future damages in a wrongful death case, where the jury's award of future damages is discounted to the date of death. The court, however, left open the question of whether the specific method used by the plaintiff in Toledo was proper. In this article we will propose the proper method that should be used in future cases.

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