At around 1:35 p.m. on May 2, 2015, plaintiff Peter Godefroy, 56, a graphic designer, was legally riding his touring bicycle with a group of cyclists on Valley Vista Boulevard, in Los Angeles. As he was in front of 13650 Valley Vista Blvd., located just east of Woodman Avenue, Godefroy hit an uplift in the road, causing him to lose control of his bicycle. He was ejected forward off of his bicycle and struck the ground. Godefroy sustained to his head, chest, knees, pelvis and a shoulder. Godefroy sued the believed maintainers of the roadway, the city of Los Angeles, the county of Los Angeles and the state of California. He also sued the owners of the adjacent property, Teresa Johnson and TNS Partners LLC. Godefroy alleged that the city, county and/or state failed to properly repair and/or maintain the roadway, creating a dangerous condition. He also alleged that Johnson and TNS Partners failed to maintain a 45 foot Shamel Ash tree, which was located adjacent to the portion of the road that allegedly caused his accident. The city brought a counterclaim against TNS Partners, alleging that the tree was on the city’s property, that the tree was not maintained, and that the tree ultimately caused the uplift in the roadway. TNS Partners ultimately settled out of the case, and all others were dismissed. Thus, the matter continued with Godefroy’s claim against the city only. Godefroy claimed that he rode over a portion of the asphalt roadway that that had been lifted up by tree roots and that the city failed to properly maintain the subject roadway, leaving the uplift in the road. He also claimed that the city’s street services performed a poor repair, which made the issue worse. Plaintiff’s counsel asserted that despite the city having notice that the uplift posed a danger and was causing flat tires to vehicles, the city failed to remedy the problem. Counsel also asserted that despite the high presence of pedestrian and bicyclist traffic in the area, and notice of the negligently maintained roadway, there were no warning signs placed to alert the public of the dangerous condition. Thus, plaintiff’s counsel contended that Godefroy hit the uplift and was launched off of his bicycle. The city denied liability and contended that Godefroy was negligent in the operation of his bicycle. The city’s counsel contended that Godefroy was unable, or failed, to see that the portion of the roadway that was raised due to the dark shade of the adjacent Shamel Ash tree. Counsel also contended that that the city only knew of the one prior property damage claim and that the subject portion of the roadway was patched following the prior claim that it had allegedly caused tire damage to a vehicle, whose driver also failed to see the uplifted area. Thus, the city’s counsel contended that the patch had begun to fail by the time that Godefroy hit it., Godefroy sustained fractures of the left temporal bone, a pelvis, both knee caps, ribs, and his left clavicle. He also lost consciousness for a short period of time, but was he conscious, but altered, by the time emergency responders arrived. Godefroy was subsequently taken to a hospital, where he was found to have a sustained a traumatic brain injury in the form of a brain bleed that required a craniotomy. He then underwent one year of rehabilitation. Godefroy was ultimately able to return to work, full time, running his graphic design company. However, he claimed that due to his traumatic brain injury, he continues to suffer from cognitive and emotional deficits, as well as changes in his personality. Thus, Godefroy sought recovery of $637,037.61 in past medical costs and more than $2 million in economic damages based on a future life care plan. He also sought recovery of non-economic damages for his past and future pain and suffering. In addition, his wife, Patricia Godefroy, sought recovery of damages for her loss of consortium.