On April 11, 2018, applicant Salvador Morales, 35, a construction worker, was in the course and scope of his employment with Construction Group Staffing when he fell four stories through an elevator shaft. Morales sustained to his head, face and chest. Morales filed a workers’ compensation claim against his employer, Construction Group Staffing, which was insured by Accident Fund Holdings Inc. Morales brought a claim against the respondent in an attempt to collect workers’ compensation benefits., Morales sustained a severe traumatic brain injury, a fracture of his jaw and fractured ribs. He was rendered unconscious at the scene. Morales was taken by ambulance to Orange County Global Medical Center, in Santa Ana, where he was diagnosed with a neurogenic bowel, a neurogenic bladder, a seizure disorder, spastic hemiplegia on the left side, a hemothorax and cognitive dysfunction. While Morales remained unconscious, he underwent an emergent craniotomy, after which he was put in a medically induced coma for approximately one month. During his hospital stay, he had respiratory complications, and he developed acute respiratory distress syndrome and methicillin-resistant Staphylococcus aureus (MRSA). As a result, Morales was transferred to Kindred Hospital – Santa Ana and then to NeuroRestorative, a provider of post-acute and subacute rehabilitation services, in Tustin, where he continued his rehabilitative care. Morales also underwent a cranioplasty in August 2018, which resulted in complications that necessitated the placement of a shunt. He was then transferred to the Casa Colina Transitional Living Center, in Pomona, for post-acute neurorehabilitation in January 2020. Morales claimed that he continues to deal with cognitive deficits. He alleged that as a result, he suffers from impaired insight, impaired emotional and behavioral self-regulation, impaired vision, impaired motor control, decreased bowel and bladder control, as well as multiple other complaints. The respondent’s counsel accepted Morales’ alleged , but disputed the nature and extent of the medical care that Morales would allegedly require.