Evidence of Poverty Preventing Injured from getting Medical Care

What is the best response to the motion below seeking to exclude evidence of my client’s “poverty”:
“Although the Courts in Oklahoma have not addressed the specific question of admissibility of evidence of a Plaintiff's alleged poverty in the context of a personal injury action, other jurisdictions have addressed this question and have generally adopted the rule that such evidence is inadmissible and irrelevant.
In the case of Gandy v. Griffin, 169 S.E.2d 651 (Ga Ct App 1969), an action was brought for personal injuries allegedly incurred as a result of an automobile collision. After a verdict for plaintiff, the defendant appealed alleging as one of the errors a statement made by plaintiff's father that they had not been able to pay the medical bills that had been incurred as a result of the collision. Defendant argued that the evidence improperly injected the plaintiff's financial condition in the case. On appeal, the court agreed. Id. at 655. The Court in Gandy went on to say that, "[t]he fact that plaintiff's father was not financially able to pay the medical bills was immaterial and prejudicial because its only purpose would be to gain sympathy for the plaintiff." Id. at 655 citing Southern R. Co. v. Black, 196 S.E.291 and Woodside Storage Co. v. Reese, 125 S.E.2d 556.
In Thornburg v. Perleberg, 158 N.W.2nd 188 (N.D. 1968), plaintiff was a passenger in an automobile driven by defendant and brought an action for personal injuries as a result of the automobile accident. During the trial, plaintiff testified that she had not undergone necessary medical treatment, because she could not financially afford the treatment. On appeal, defendant argued that the admission of such evidence was highly prejudicial, and the court agreed, stating that, "... it has always been held to be prejudicial error to admit evidence of the poverty of the plaintiff in personal-injury action." Id. at 194. Furthermore, the Court, citing cases from numerous jurisdictions, noted that the admission of evidence of poverty of the plaintiff is never allowed in an action for compensatory damages. Id. at 194 citing Oakes v. Baker, 192 P.2d 460; West v. Twin City Motor Bus Co., 52 W.2d 442; Suzore v. Rutherford, 251 S.W.2d 129; Wilmoth v. Limestone Products Co., 225 S.W.2d 532; Love v. Wolf, 38 Cal. Rptr. 193; Hedge v. Midwest Contractors Equipment Co., 202 N.E.2d 869; Pyles v. St. Louis Public Service Co., 372 S.W.2d 114; and Single v. Union Pacific R.R. Co., 119 N.W.2d 680.”

Answer: My experience is that the court will not let the evidence of poverty in unless the defendant "opens the door to it" by arguing that the patient didn't get the treatment he or she would have needed if they were really hurt. Under those circumstances, the courts seem usually to say that the evidence is admissible to rebut such an assertion by the defendant.