On Dec. 19, 2013, plaintiff Kian Kiani, 66, a retiree, was bicycling on Valmar Road, a one-lane road that opens into a three-lane road, in Los Angeles, with two dedicated left turn lanes and one right turn lane. As Kiani was turning right onto Mulholland Drive, his bicycle collided with the rear of a vehicle operated by Ingermar Hulthage, who was also attempting a right turn onto Mulholland Drive. Kiani was ejected from his bicycle and struck the pavement. He sustained to his face, head and a shoulder. Kiani sued Hulthage, alleging that Hulthage was negligent in the operation of his vehicle. Kiani claimed that Hulthage cut him off at the last minute before the turn and was the cause of the collision. Plaintiff’s counsel noted that there was a witness to the accident, but the witness gave conflicting testimony at trial. Hulthage claimed that Kiani was to blame for riding the bicycle into the rear of his vehicle. Plaintiff’s counsel noted that the defense’s bicycles expert did not examine the vehicle, the bicycle or Hulthage’s testimony and that the expert was impeached by Hulthage’s testimony, which differed from his opinion., Kiani sustained fractures to his face, including the zygomatic arch; a traumatic brain injury, inclusive of intracranial hemorrhage; an acromion fracture of his left, non-dominant shoulder; and abrasions all over. He was transported to West Hills Hospital, in Los Angeles, and his CAT scan was positive for an intracranial hemorrhage. Kiani required some neurosurgical assistance, but he had no surgeries for his head or shoulder. Kiani claimed he suffers from cognitive impairments as a result of his brain injury. He also claimed he became withdrawn and depressed after the accident and that he does not interact with people as he did before. The plaintiff’s treating neurology expert, who saw Kiani at West Hills Hospital, opined that Kiani sustained a TBI, as evidenced on the CAT scan. However, the expert testified that Kiani’s cognitive impacts and depression were all objective symptoms and that no one could say what caused them. Kiani sought recovery of $10,800 in past medical costs, which was stipulated to by the parties. Kiani also sought recovery of non-economic damages for his past and future pain and suffering. His wife, Soraya Kiani, initially presented a loss of consortium claim, but it was ultimately dismissed. Defense counsel contended that all of Mr. Kiani’s residual were pre-existing, as there were records of depression before the incident. In response, plaintiff’s counsel argued that although depression was mentioned in Mr. Kiani’s prior medical records, Mr. Kiani never previously sought psychological care for any great period of time. Counsel also noted that the defense’s neurology expert did not perform a neuropsychological assessment, as Mr. Kiani only speaks Farsi, and, instead, the expert had another neurologist, who speaks Farsi, perform he exam. When plaintiff’s counsel questioned why the defense expert did not have an interpreter, the expert responded that Mr. Kiani’s responses did not matter, but the nuances did.