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.