Generally speaking, aside from very specific types of cases involving contracts, or specific types of statutory
relief, a Plaintiff typically includes counts for things like NIED (negligent infliction of
emotional distress), pain and suffering, loss of consortium, loss of future earning capacity — these are a few of the types of counts whereby there is no specific value a defendant could ever point to being «fully satisfied» — the reason being, a jury needs to
determine the legitimate value of these claims unless the Plaintiff accepts a settlement award whereby he / she / it feels as if it's fully satisfied.