The Traditional Lump Sum Award:

For centuries the Courts in Common Law Jurisdictions have been assessing damages on a once-off lump sum basis. However, whilst the lump sum award had great attraction and benefit for the great majority of cases, the lump sum approach has proved to be problematical in dealing with catastrophic injury cases. The problem is that assessing damages on a lump sum basis to assess future needs over a prolonged period of time has proved to be a wholly inaccurate exercise prone to serious error. There have been many Judicial pronouncements over the years, criticizing the lump sum approach. For example, Lord Scarman stated:1

"The award which covers past, present and future injury and loss must, under our Law, be a lump sum, assessed at the conclusion of the legal process. The award is final. It is not susceptible to review as the future unfolds, substituting fact for estimate. Knowledge of the future being denied to mankind, so much of the award as is to be attributed to future loss and suffering – in many cases the major part of the award – will almost surely be wrong. There is really only one certainty. The future will prove the award to be either too high or too low."

Another commentator stated:2

"The inherent fallibility of the “snapshot” approach to evaluating a Plaintiff’s future loss has been widely considered. It is generally accepted that the multiplier/multiplicand approach is almost guaranteed to miss the mark of fair and just compensation. It’s usually providence and not science which decides whether the lump sum leaves the Plaintiff unjustly enriched or undercompensated."

The above quotes encapsulate the enormously difficult task faced by the Courts when trying to assess damages for future loss and expense on a once-off, lump sum basis. Under the current system in Ireland, this is the only form of compensation permitted. Whatever happens after the award has been made will not affect the position. Thus, even where the medical evidence given in the case is entirely refuted by subsequent events, nothing can be done to undo the error. This approach has been criticised on the basis that to appraise the value of a chance in the future, “is bound to result either in a windfall or a denial of adequate redress to the Plaintiff”.3

The various problems with the lump sum award approach when dealing with catastrophically injured persons could be summarized as follows:

  • Uncertainty as to prognosis
  • Difficulties in predicting life expectancy
  • Difficulties in predicting future care needs
  • Difficulties in predicting future costs of aids, appliances and equipment
  • Technological or medical advances making available unforeseen and uncosted new treatments
  • Expensive assistive technology and equipment not budgeted for in the original award
  • Uncertainty as to State provision/Social Welfare entitlements
  • Uncertainty as to the correct rate of return on investment assumption to make for the actuarial calculation
  • Uncertainty as to the rate of future inflation, particularly medical inflation
  • Risk of investment strategy not achieving expected returns e.g. collapse in “Irish bank shares” or equity markets generally.

Is There A Real Risk Of A Catastrophically Injured Plaintiff Being Undercompensated Using A Lump Sum Award Approach?

At the current time, actuaries routinely use a discount rate of 3% when calculating future loss.4 In other words, the assumption is made that the investment returns on the lump sum will exceed the rate of inflation by a further 3% throughout the entire period of loss. It has also been held that the Plaintiff is not to be expected to take risky investment decisions that will put his capital at risk and thus the Court has held that the Plaintiff is to be entitled to invest the lump sum in low risk asset classes. I have been advised by numerous economists and actuaries that the real rate of return on risk-free assets/investments achieved over the past several decades (i.e. Government Bonds, presumably excluding Irish Governments Bonds!) is in fact of the order of 1% above the rate of inflation. Thus if the principles set out in the House of Lords decision in Wells and Wells.5 and in the Irish High Court Boyne v Dublin Bus were properly applied then victims receiving awards at the current time should be expecting their compensation to have been calculated at a discount rate of about 1%. Instead, the awards are being calculated making an optimistic assessment of 3% real rate of return.6

The disparity between the discount rate that should prevail under current conditions (1%) and that currently being applied by the actuaries routinely in personal injury actions gives rise to serious under-compensation. Even if one were to assume a discount rate of 2.5% which is often achieved by Plaintiff lawyers who have the temerity to challenge the conventional approach, the figures are quite remarkable.

For example, a 10 year old boy who has been awarded future care costs of €100,000 per annum should for parity with current market conditions (i.e. 1% discount rate), should be receiving a lump sum award of €5,270,000 whereas in practice using the best discount rate currently on offer (2.5%) he would only receive €3,370,000 i.e. a shortfall of €1,900,000 or 36%. This is before one considers at all the impact of medical inflation.

In effect the Court is saying that it is compensating him €100,000 per annum to purchase future care but is in fact only offering enough to purchase €64,000 per annum at risk free rates. This is not quite what the layman would understand as restiutio in integrum.

What Can The Plaintiff Do Faced With Such A Prospect Of Under-Compensation?

Assuming he is hell bent on taking the lump sum settlement, he needs to stretch the €3,370,000 to produce an income of €100,000 per annum for life. An investment in risk-free investments, as envisaged by Wells –v– Wells etc, will only provide an income of €64,000 per annum given the current yield on such investments. To produce a bigger income, he has no other option but to take a risk with his investments (say a carefully constructed portfolio of equities and bonds) in anticipation of generating a sufficiently high yield to make up the shortfall. He may succeed with this strategy and all will be well. On the other hand he may fail and his income might even transpire to considerably less than the €64,000 he could have had on a guaranteed basis by only locking into Government bonds/stock. Presumably the expectation is that the welfare state will then bail him out if all else fails which of course raises a question about whether it is right for tax payers to be subsidising Defendants.

In conclusion it seems to this writer that over the past decades the Courts have made the wildly over-optimistic assessment that real rates of return of 3 or 4% above inflation can be earned without any real risk. However, the series of collapses and rallies in the equity markets and complete failure of the Irish banking system in recent times should offer cogent evidence of the risk inherent to an investor of investing capital in so called blue chip risk free investments. It’s worth bearing in mind that a paraplegic who requires 24 hour care to have a modicum of comfort is unlikely to have the same attitude to investment risk as Warren Buffett! It’s hardly appropriate to be telling a paraplegic, confined to a wheelchair that they will have to tighten their belt in times of low yields and returns on the stock markets and wait for the return of the Bull market. It is not possible for such a Plaintiff to tell their carer that they can only be paid two thirds their agreed wages pending an improvement in investment returns!

I know from my own personal knowledge of real cases where lump sum awards have been invested by the Wards of Court Office in so called blue chip investments/equities including Irish bank shares bought with part of the lump sum awards in the middle of the last decade. These substantial investments which were made as part of the investment portfolio are now effectively worthless with a consequential adverse effect on the future cumulative rate of return likely to be achieved over the life time of the injured Plaintiff.

Against this background, one would think that any Plaintiff contemplating accepting a lump sum award would be extremely foolish if an annual index linked payment was available as an alternative.

Developments In The UK

The Damages Act, 1996 introduced the periodic payment orders PPO but only by consent. Thus, if a claimant wanted a PPO a Defendant didn’t have to provide one. Therefore there was no real force behind the legislation. As a consequence, in reality, no periodic payment orders were made in the years after the 1996 Act. Then in 1999, the House of Lords in Wells and Well strongly endorsed the notion of periodic payments and in effect urged Parliament to introduce the necessary legislative changes to permit the Court to impose periodic payment orders where it was in the best interests of the parties.

In the Courts Act, 2003, Courts were given the power to impose a periodic payment provided security of payment was enhanced with 100% protection from a guarantee from the State.

However, a major problem remained, namely the question of indexation. The PPO still remained unpopular with Plaintiffs primarily because the annual payment was index linked to the retail price index and not inflation in carer’s salaries. In general over the past number of decades inflation in carers wages has exceeded inflation measured by the RPI by about 2% per annum in the UK

Section 2(8) of the Damages Act, 1996 as initially interpreted by the Courts invariably meant that the annual or periodic payment would be varied by inflation linked to the retail prices index (equivalent to our CPI Index). However, Section 2(9) of the Act did provide that the Court could make an Order dis-applying the earlier sub section or modifying the effect of the earlier sub-section.

In the Thompstone group of appeals7, the Court of Appeal in a group of 4 conjoined cases, were asked by the Plaintiffs to make an Order dis-applying the application of the retail price index for the purposes of calculating the future inflation. Instead the Court of Appeal was invited to consider various alternative, more appropriate inflation indexes which more accurately reflected the inflation in items more applicable to the Plaintiff’s cost of care. In the end, the Court of Appeal found in favour of the Plaintiffs and decided that the most appropriate index, against which to measure inflation, for the purposes of calculating periodic payment orders was ASHE 6115 which effectively was the sub indice of the Annual Survey of Household Income measuring the inflation in the salaries of care assistants and home carers.

This survey is maintained by a Government agency and is published in the Autumn of every year. Each year practically without exception over the past 12 years the ASHE 6115 index rose by 2% per annum in excess of the retail price index. There is no reason to believe that the results would be any different if a similar calculation was done in this country.

It will be readily seen from the foregoing that a periodic payment order linked to inflation in carers wages is likely to be far more valuable than a lump sum award which makes an artificially high and optimistic assessment of the likely real rate of return.

Applying all of this to the 10 year old victim mentioned above, assuming his representatives are getting some decent advice and haven’t already accepted a lump sum settlement, he is now, in the UK, (post Thompston), entitled to avail of a PPO to compensate for future care costs in which case he will now receive €100,000 per annum, index linked to ASHE 6115


He can ask for a lump sum settlement with the accompanying double error of the wrong discount rate which is then applied to an inferior multiplier for future care costs.

Given the magnitude of the error implicit in the discount rate currently applied to lump sum awards and the inferior indexation associated with the lump sum award, any advisor recommending a lump sum settlement where a periodic payment order, appropriately index linked is an alternative offer would seriously need to ask if it was good advice to elect for the lump sum.

I reproduce immediately below 3 graphs from a UK financial expert8 to illustrate the discrepancy in monetary values between the 2 methods of compensation.

Increase In Periodical Payments Over Time

Increase In Periodical Payments Over Time

Total Amount of Periodical Payment Received Over Time

Total Amount of Periodical Payment Received Over Time

Discounted Value of the Periodical Payment

Discounted Value of the Periodical Payment

Recent Developments In Ireland

The Law Reform Commission, in its report on personal injuries periodic payments and structured settlements published in 1996 recommended wide ranging reforms in this area. It proposed that there should be a provision in Law for interim awards, provisional awards, periodic payments and the use of structured settlements which should be tax exempt under the extended terms of Section 5 of the Finance Act, 1990. Unfortunately, these recommendations found no favour until recent times and apparently the Legislator and/or the Insurance Industry were not keen to act on these recommendations.

As many of you will be aware, over the past number of years, Judge Quirke the Senior Personal Injuries Judge of the High Court, has been a strong advocate of the introduction of a period payment order regime for catastrophically injured Plaintiffs. In February 2010 the President of the High Court, established a working group on Medical Negligence Litigation and Periodic Payments which included amongst its terms of reference:

"to consider whether certain categories of damages for catastrophic injuries can or should be awarded by way of periodic payment orders and to make such recommendations to the President as may be necessary."

This group was chaired by Mr Justice Quirke and contained a number of other Judges of the High Court together with a number of Senior Counsel, Solicitors and representatives of the Irish Insurance Federation, the State Claims Agency and all of the relevant government departments. This group met on 9 occasions and consulted widely with other stakeholders and received excellent advice from a number of experts in particular from the UK. The working group produced its report on periodic payments (Module 1) which was presented to the Government in November 2010.9 In summary, the principal recommendations of the report were:

  • Legislation should be enacted to empower the Courts as an alternative to lump sum awards of damages to make it consensual and non-consensual period payment orders to compensate injured victims in cases of catastrophic injury where long term, permanent care will be required for the costs of:
    • Future treatment
    • Future care
    • The future provision of medical and assistive aids and appliances.
  • Where the Court considers it appropriate and in the best interests of that person that such an Order should be made, provided that the parties have been given an opportunity by the Court to make submissions and be heard in full on the relevant issues.
  • The Court should be empowered to make periodic payment orders to compensate for future loss of earnings only with the consent of all of the parties to the relevant claim.
  • Periodic payment orders may only be made in circumstances where the Court is satisfied that continuity of payment under the periodic payments order is reasonably secure.
  • The State, through the NTMA should be empowered to provide injured victims with the necessary security for periodic payments, either by the provision of annuities to insurers and others or in such other manner as may be appropriate.
  • Provision within the legislation must (emphasis added) be made for adequate and appropriate indexation of period payments as an essential pre-requisite for their introduction as an appropriate form of compensation. In particular the Group recommends the introduction of earnings and cost-related indices which will allow periodic payments to be index linked to the level of earnings of treatment and care personnel and to changes in costs of medical and assistive aids and appliances. This will ensure that the Plaintiffs will be able to afford the cost of treatment and care into the future. The group further believes that the competence and independent status of the CSO uniquely qualify it to compile and maintain the indices required.
  • Variation of PPO should be permitted where it has been determined that the Plaintiff’s condition will seriously deteriorate or significantly improve and where this future contingency has been factored into the original PPO.
  • It should also be permissible at the time of making a periodic payment order only to provide in that Order for “stepped payments” vis the adjustment on the attainment by the Plaintiff of a particular age or ages for the periodic payments as indexed to reflect an increase or decrease in living or care expenses.
  • Legislation providing full and comprehensive exemption from income tax for such payments should also be enacted.
  • Provision should be made in the primary legislation confirming and clarifying the availability within this jurisdiction of interim provisional awards of damages.

Advantages Of Periodical Payments Over The Lump Sum Approach

If one makes the assumption that the legislation is introduced in line with the working party’s report and draft legislation and in particular that the periodic payment order is linked to a reliable annual index of inflation in carer’s wages/salaries one will readily see that there are huge potential advantages to periodic payment orders from the Plaintiff’s point of view. In summary the advantages are:

  • No tax to pay on the annual PPO
  • Payments are protected by proper security i.e. an effective guarantee from a State body (NTMA)
  • Payments are for life regardless of how long the Plaintiff lives i.e. removes all risk on life expectancy issues from the Plaintiff
  • It provides the Plaintiff with certainty in an uncertain world and this should not be under estimated in the current volatile and economically uncertain climate – puts the investment risk back onto the tort feasor
  • Periodic payment will increase in line with the expenditure on care costs – linked to inflation in carer’s wages not the CPI – the risk of high inflation again placed on the tort feasor
  • If we assume that carers wages inflation will continue to increase at a higher rate than general prices inflation (CPI) then a PPO increasing by inflation in carer’s wages is worth considerably more to a Plaintiff than a lump sum in the long run.

The Current Position In The UK (Post Thomstone)

  • In 2005, before the Court of Appeal decision in the Thompstone group of cases, when periodic payments were linked only to the retail price index and not carer’s wages (ASHE 6115) most claimants did not want PPOs.
  • However, over the past 5 years, the situation has dramatically turned around and now most claimants in the UK want PPOs because:
    • There is security (“where else can I put my money?”)
    • There is indexation to an appropriate wages index
    • Claimants are now educated as to the advantages by receiving proper financial and legal advice from their advisors
  • There have now been approximately 1,000 PPO awards, the great majority, approximately 80% of which have involved cases brought against the State.

What Is Currently Happening With Catastrophic Injury Claims In Ireland (2010/2011)?

At the moment, and in anticipation of the Government introducing the legislation which has been recommended by the President’s Working Group, many catastrophic injury cases are being adjourned for a period of up to 2 years to allow the necessary time to introduce the legislation. In the meantime, many of the cases are being dealt with by way of an interim award of damages. At this stage there must be more than a dozen such cases having been dealt with in this way. Our firm has had the experience over the past 9 months of dealing with four such cases in this way. The option of having the case dealt in this way can only be availed of if the State are the Defendant or the paying party. It would not be advisable to deal in this way with an action against a Defendant privately insured least there be any prospect of default or business failure between now and the introduction of a PPO scheme which had proper protection/security of payment mechanisms in situ for the Plaintiff.

Typically these interim settlements/interim awards have been made up of a full and final settlement of certain heads of damage, (usually general damages, past care, loss of earnings to date, future loss of earnings), together with an allowance for the estimated costs of two years future care and two years aids, appliances and assistive technology. Agreeing the claim for future housing has proved problematical in recent times. Typically cases are settled on the basis of an interim payment for housing needs and it has not usually proved possible to agree final amounts for housing costs, as a Judgment of the High Court is currently awaited on this issue (Barry v National Maternity Hospital).

Lest anyone thinks it has been an easy task to agree interim awards in such circumstances in the writer’s experience it has proved extremely difficult. Often, negotiations are very protracted and novel issues have arisen in several of the cases which our firm have been involved with. We are very much feeling our way.

The Future?

If I could digress from discussion of PPOs for a moment, to make a broader but vital point. Last year at this conference, the Chairperson of AvMA, Mr Peter Walsh, and others, called for the introduction of a duty of candour into Irish Law to compel health professionals to own up candidly to their patients when they know the patient has been injured due to sub-standard care. I would like to again endorse and repeat that call. I hope it’s not wishful thinking on my part, to hope that such a law would be introduced in this country. Due to AvMA’s tireless campaigning in the UK it is my understanding that the current UK Government has given a commitment to introduce such legislation.

Apart from reducing the trauma and distress suffered by patients and their families, such a duty of candour could make a significant contribution in substantially reducing the amount of legal and associated costs arising from unnecessarily contested medical negligence actions. There is the potential to save a huge amount of costs if liability were to be admitted at an early stage. Not only could lawyers costs be saved but a very significant amount of administrative costs, incurred at the hospitals involved, within the HSE and within the State Claims Agency could be reduced also.

Such a duty of candour would be entirely consistent with the Department of Health’s own findings in its 2008 report, (which was endorsed by the then Minister for Health, Mary Harney) which stated:10

"Studies show that openness can decrease the trauma felt by patients following an adverse event and that patients often forgive the medical error when it is disclosed promptly, fully and compassionately and action is taken to make sure it doesn’t happen to another patient. The over-riding principle accepted by the Commission is that patients are entitled to expect honest and open communication in relation to an adverse event that may have caused them harm".

Such a duty of candour is entirely consistent with the latest ethical guidelines published by the Irish Medical Council in November 2009 which at paragraph 18(3) states:

"Patients and their families are entitled to honest, open and prompt communication with them about adverse events that may have caused them harm".

The Working Party established by the President of the High Court is currently working on its second module which will be proposed amendments to the Rules of Court governing Medical Negligence claims. It is to be anticipated that the Working Party will look closely at pre-action protocols which hopefully will endorse and encourage the principles enunciated in the aforementioned reports and guidelines. I, personally, would wholeheartedly endorse the approach of “cards on the table” at the earliest possible time. In my own experience, when doctors and hospitals candidly own up at an early stage, patients can be very forgiving and even if a legal claim is pursued the patient’s settlement expectations are very modest indeed. Several States in America have adopted such an approach with remarkably encouraging results which demonstrate that the cost of settling claims, both in terms of damages and legal costs, have been very significantly reduced.11 Such an approach would require a fundamental change in attitude and culture and if ever there was a time for some radical reappraisal of how things are done it is now.

Back now to PPO’s. It is hard to know whether or not the report of the Working Party will in fact be acted upon and legislation introduced by the Government. It is in their programme for Government and thus there must be a fair chance of it being introduced. The only caveat I would put is that somebody in the Department of Finance is sooner or later going to run the numbers and realise that in the long run the costs of a regime of PPOs could overall cost the State more than the current lump sum system. There will be a cash flow benefit to the State for a few years before the chickens come home to roost as it were! As I hope is clear from the graphs set out above, the total sum likely to be paid out under a PPO to a long survivor is significantly in excess of what the value of a lump sum award is even allowing for inflation etc. Thus, asides from the peace of mind and security afforded by a PPO regime there is likely to be a significant financial gain/benefit for many Plaintiffs. It’s an open question whether such increased payments for long surviving Plaintiffs would be offset by savings derived from Plaintiffs who die prematurely shortly after the making of the PPO.

My own prediction is that if a PPO system is introduced negotiations are going to become far more protracted and lawyers are going to have to spend a great deal of time before commencing settlement negotiations preparing proper paperwork and proper detailed schedules of loss and damage. The traditional broad brush approach and swings or roundabouts attitude will no longer suffice. Difficulties will arise when there is a shortfall in recovery of the capital costs of a major item and it will be difficult to make it up under a different head of damage. It was possible to make good shortfalls, or disguise shortfalls, in certain heads of damage when a large lump sum award was being made. This is simply not going to be possible when the award is being in effect converted into an annual payment.

Personally I would have no hesitation in advocating any client of mine should avail of a PPO provided there is proper security for payment and crucially provided that the index of inflation is to the rate of increase in wages/salaries of carers and not the general CPI. The position in England as stated above now is that the vast majority of Plaintiffs will elect for a PPO, at least in respect of future care costs.

There remains the vexed question of how to deal with a shortfall in the award under the heading of accommodation/housing costs. The law will be clearer following Judge O’Neill’s Judgment being delivered in Barry v National Maternity Hospital. It will be interesting to see whether the Irish Courts follow the same approach as adopted by the UK Courts in the case of Roberts v Johnson.12 If it does, I can foresee significant practical problems arising for Plaintiffs of poor means, with no existing house and with a shortened life expectancy. If there is going to be a substantial housing shortfall, I can foresee many Plaintiffs electing to have the “aids and appliances” head of damage dealt with on the traditional lump sum approach so as to utilise some of the damages awarded under this heading to make up the shortfall on housing acquisition costs. This is what currently occurs in the UK and I can see it being followed here. Thus, my prediction is that Claimants will elect to have an award made up of a lump sum to deal with past losses, general damages, past and future loss of earnings and possibly aids and appliances. Thus the PPO will most likely deal solely with the vexed question of future care. This element currently makes up approximately two thirds of the award in the traditional lump sum award in a catastrophic injury case.

As practitioners we are all going to have to undergo some significant re-education and learning. The Orders that are going to have to be drafted when and if these cases are settled or determined by the Court are going to be radically different to what exists now. I have seen some of these Orders that are routinely used in the UK to deal with PPOs and they can run to some twenty to thirty pages with several schedules setting out complicated mathematical formulas for dealing with the various heads of damage and calculations of the inflation rates, stepped payments and wage scales for different future heads of damage. In addition it is likely that we are all going to have to have the benefit of sound experienced financial advice at the time of negotiating these settlements and the input from a financial advisor, familiar with the issues involved so as to minimize the possibility of serious mistakes being made with drastic consequences for either Plaintiffs or Claimants.

In the long run however, I think that if the report of the Working Group is acted upon it will significantly improve matters for the catastrophically injured Plaintiff who will have a far better, more equitable and more accurate assessment of their financial needs to cover their life time care costs. It will place all of the investment and life expectancy risks back on to the Defendant tort feasor which is where they should be and give the Plaintiff peace of mind.

1 Lim Po Choo –v– Camden and Islington Health Authority {1980 AC 174}

2 Bevan Nicholas “The New Periodical Payments Regime (2005) 2 Civil Court News”

3 Fleming on Torts, page 256

4 Following the decision of Finnegan J in Boyne –v– Bus Atha Cliath [2002] IEHC 135

5 Wells v. Wells [1998] 3 All ER 481

6 In fact from the mid 1980’s for approximately 20 years until Boyne –v– Dublin Bus the actuaries were using a discount rate or real rate of return assumption of 4%

7 Thompstone –v– Thameside and Glossop Acute Services NHS Trust [2008 2 AII.E.R. 537]

8 Reproduced from data compiled and provided by I.M. Asset Management

9 Working Group on Medical Negligence and Periodic Payments Report (Module 1) October 2010 –

10 The Commission On Patient Safety and Quality Assurance of the Department of Health Report published July 2008 entitled “Building a Culture Of Patient Safety”.

11 E.g. University of Michigan Health System covering 40 hospitals in the greater Chicago area – see “A Better Approach To Medical Malpractice Claims, The University of Michigan Experience, The Journal Of Health And Life Sciences Law January 2009 by Boothman et al” which demonstrated declining claims from 262 in 2001 to 83 in 2007 with a reduction of claims reserves from $73 million to $13 million after the policy of honesty and apology was introduced.

12 Roberts v. Johnstone [1989] 1 Q.B. 878

Presented by Augustus Cullen Law to the AVMA Dublin Conference on 11 May 2011.

11 May 2011

    Dear Joice… you are and have been very professional, sympathetic and dignified in all of your dealings with us and I put that down to one simple fact. You listened.

    James, Medical Negligence Client

    Neil is an absolute gentleman to deal with – kind, tactful and very efficient. We could not praise him highly enough. He brought us through a horrible time.

    Sean, Medical Negligence Client

    Many thanks again for a job well done. We really appreciate all your hard work and practical advice.

    Corporate client in a commercial litigation matter

    Dear Jamie, You and your team in ACL were so professional, diligent and prompt. I have recommended you and the firm, and will continue to do so.

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    Gus Cullen and the firm’s approach to addressing the key issues was professional, yet personal, efficient yet attentive.


    The process is a difficult one and when you deal with people who are so professional and yet genuine/real people, it makes it so much easier... so thanks a million.


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