Plaintiff, a 59 year old woman, was visiting her husband who was an in-patient at defendant’s hospital when she claims that she slipped on something on the floor in his room and fell. Plaintiff’s alleged fall was unwitnessed, even by her husband. Plaintiff had myriad lien physicians retained by her attorneys who recommended at least three elective surgeries to her neck, knee, ankle and foot. It was discovered that plaintiff had a prior trip and fall with similar surgical recommendations. Trial was approaching and was firm as plaintiff’s counsel had previously sought a continuance. A Mandatory Settlement Conference was unsuccessful. Informal negotiations amongst counsel just prior to expert designation yielded a resolution.