Dr. Steward was retained to calculate economic damages of an undocumented worker who was severely injured in a car accident. Dr. Steward used two different work life scenarios. In the first scenario, I assume that the over the plaintiff’s expected work life, he would have worked in the U.S. for a period of time and then returned to Mexico had he not been injured. Additionally, it is also expected that the plaintiff will need between to pay for the medical services and items that the plaintiff’s life care planner projects that he will need over his remaining life time. In the second scenario, it was assumed that the plaintiff would have worked in the U.S. over his entire expected work life had he not been injured. In both scenarios it is assumed that the plaintiff will not be able to return to the work force now that he has become injured. In both work life scenarios, the plaintiff’s U.S. non-injury earnings capacity is based on his earnings history at the time of his injury. The statistical model, called a Cox proportional hazards model, calculates the likelihood that a Mexican migrant work will be active in the U.S. work force in any given time. The statistical calculation accounts for factors such as the plaintiff’s demographics, education, and geographical location.