IS CHALLENGED HERE AS BEING OUTDATED, AND UNJUST, WHEN THE OHIO BUREAU OF WORKERS COMPENSATION IS BY OHIO STATUTE BEING BROUGHT IN AS A PARTY MAKING A CLAIM PRIMARILY TO REIMBURSE THE OHIO BUREAU OF WORKERS COMPENSATION NOT ONLY FOR EXPENDITURES MADE BUT FOR THOSE CONTEMPLATABLE. SHOULD IT NOT BE DECLARED TO BE AGAINST PUBLIC POLICY AS TO PREVENT AN INSURANCE COMPANY FROM HAVING AN ADVANTAGE OVER THE OHIO BUREAU OF WORKERS COMPENSATION WHICH IS ANOTHER INSURANCE PROVIDER FUNDED BY PUBLIC FUNDS AND EMPLOYERS' PREMIUM PAYMENTS? THE ERROR THEREFORE ALLEGED IS THAT THE COURT PREVENTED THE JURY FROM KNOWING THERE WAS AN INSURANCE COMPANY HERE PAYING FOR THE DEFENSE OF MR. HALL AND WOULD HAVE BEEN LIABLE FOR HIS NEGLIGENCE AND DID PAY FOR THE DAMAGES TO THE EMPLOYERS (SIC) VEHICLE OPERATED BY PLAINTIFF APPELLANT.
VII THE COURT LIMITED EVIDENCE OF THE CLAIM OF THE OHIO BUREAU OF WORKERS COMPENSATION TO BE INTRODUCED TO THE JURY BUT ALLOWED THE PLAINTIFF TO ARGUE SAID CLAIM. THIS HANDICAPPING OF THE PLAINTIFF WAS DESTRUCTIVE TO THE OHIO BUREAU CLAIM AND ALSO TO THE CLAIM OF THE PLAINTIFF-APPELLANT.
VIII THE COURT WAS PRESENTED WITH STATUTORY AUTHORITY, 4123.931, REINFORCED BY THE PLAINTIFF'S ISSUING THE STATUTORY NOTICES AND PLEADING THE OHIO BUREAU INTO THE POSITION OF BEING A PARTY CLAIMANT IN THE PRIMARY CASE AGAINST A THIRD PARTY JOINT TORT FEASOR WHICH THE ATTORNEY GENERAL ANSWERED BUT FAILED TO PLEAD THE BUREAU'S CLAIM, AND THE COURT ALLOWED THE BUREAU TO HAVE THE BENEFIT OF 4123.93 INSTEAD OF HOLDING THE BUREAU TO THE OBLIGATIONS SET FORTH UNDER 4123.931 AGAINST NOT ONLY THE BUREAU'S INTERESTS BUT PREJUDICIAL TO THE INTERESTS OF THE PLAINTIFF-APPELLEE. (SIC)
IX TRIAL COURT DIRECTED JURY TO ANSWER GENERAL VERDICT QUESTION FIRST AND IF FOR DEFENDANT TO IGNORE OTHER QUESTIONS. DETERMINATIVE ISSUES WHETHER ISSUES OF FACT OR MIXED WERE NOT GIVEN TO JURY TO ANSWER FIRST, WHICH IS OPPOSITE TO REQUIREMENT OF OHIO CIVIL RULE 49.
X TRIAL COURT DID NOT SUBMIT APPROPRIATE QUESTIONS FOR DETERMINATION OF ISSUES WHETHER ISSUES OF FACT OR MIXED ISSUES OF FACT AND LAW NOR GIVE APPROPRIATE INSTRUCTIONS CONCERNING THEM. THUS JURY WAS NOT LED TO THE VERDICT APPROPRIATELY AS REQUIRES (SIC) BY OHIO CIVIL RULE 49.
XI THE TRIAL COURT IGNORED 4123.931 REVISED CODE BY EXCUSING THE OHIO BUREAU FROM PERSUING (SIC) ITS CLAIM WHEN THE PLAINTIFF-APPELLANT APPROPRIATELY MADE THEM A PARTY TO THIS ACTION.
XII TRIAL COURT DID NOT INSTRUCT JURY AS TO WHAT CONSTITUTED AGGRAVATION OF PRIOR INJURIES.
XIII TRIAL COURT DID NOT INSTRUCT THE JURY REGARDING DEGREE OF PROOF OF INJURY EXCEEDING PRIOR INJURIES.
XIV TRIAL COURT RETURNED REJECTED EXHIBITS TO ATTORNEY AND DID NOT REQUIRE EXHIBITS REJECTED ALL TO BE PRENUMBERED BEFORE INTERROGATION OF WITNESSES AND DID NOT RETAIN FOR COURT FILES THOSE EXHIBITS AND WAS UNABLE TO HAVE RETURNED EXHIBITS IDENTIFIED BY THE RECORD.
As an initial matter, we note that appellant's brief sets forth the bulk of her arguments in one unbroken section running thirty-two pages in length. Pursuant to App. R. 16(A)(7),