On July 28, 2015, plaintiff Carlos Perez Sr., 44, an automobile upholsterer, was driving to work with his son, plaintiff Carlos Perez Jr., when they came to a complete stop in traffic on Jefferson Boulevard, in Los Angeles. After a minute or two, their vehicle was involved in a collision with a vehicle operated by Kailey Gullett. The elder Perez claimed that he sustained an injury of his left shoulder. The Perezes sued Kailey Gullet and the owners of her vehicle, Donald Gullett and Sharon Gullett. The Perezes alleged that Kailey Gullett was negligent in the operation of her vehicle and that Donald and Sharon Gullett were vicariously liable for Kailey Gullett’s actions. The younger Perez was ultimately removed as a plaintiff, and Donald and Sharon Gullett were dismissed from the case before trial. The elder Perez claimed that he was traveling from Beverly Hills to Marina del Rey when he came to a complete stop in traffic. He claimed that, while stopped, his vehicle was rear-ended by Kailey Gullet’s vehicle, which was traveling 9 to 13 mph. Gullet claimed that she came to a complete stop approximately 10 feet behind Perez’s vehicle and stayed there for roughly one to two minutes before Perez reversed his vehicle and backed into her vehicle at 1 to 2 mph., Perez claimed he sustained a tear of the left, nondominant shoulder’s glenoid labrum from anterior to posterior (commonly termed an “SLAP” lesion). Perez went to work after the collision, and he did not seek medical treatment for one week. However, he claimed that he experienced slight pain and discomfort to his left shoulder on the day of the incident, but that it gradually got worse over time. He received chiropractic care and cortisone injections over the next year. Perez ultimately underwent a surgery to repair his torn glenoid labrum. Plaintiff’s counsel contended that Perez did not suffer the same or similar to the left shoulder prior to the subject collision and that there were no medical records or diagnostic film studies that predated the incident. Perez’s accident-reconstruction expert opined that Gullett was traveling 9 to 13 mph at the time of the collision and that the estimated Delta-v was 8 mph, which he opined was sufficient force to cause the type of injury Perez alleged. Perez missed several months of work after the shoulder surgery. Although the procedure was a success, Perez claimed that he still experiences slight pain and discomfort. He contended that his shoulder pain limits the amount of time he can work as an auto upholsterer. Perez sought recovery of $75,995 in past medical costs. He also sought recovery of noneconomic damages for his past and future pain and suffering. The defense’s expert orthopedic surgeon opined that Perez’s were degenerative and long-standing, but conceded that Perez suffered no more than a sprain and/or strain to his left shoulder. The defense’s accident-reconstruction expert opined that the Delta-v of the crash was 4 to 6 mph, which he opined would likely result in no injury. In response, plaintiff’s counsel argued that the testimony of the defense’s accident-reconstruction expert contradicted the testimony of the defense’s expert orthopedic surgeon, who claimed that Perez sustained a sprain and/or strain. Plaintiff’s counsel also argued that the defense’s accident-reconstruction expert was forced to admit that if Perez traveled 10 feet in reverse at 1 to 2 mph before making contact with Gullett’s vehicle, as Gullett claimed, then it was physically impossible to have a Delta-v of 4 to 6 mph, as the defense expert claimed. Additionally, plaintiff’s counsel argued that the defense’s accident-reconstruction expert was forced to admit that if Perez traveled 10 feet in reverse at 1 to 2 mph before making contact with Gullett’s vehicle, as Gullett claimed, then it would have taken 6.9 seconds before Gullett’s vehicle was struck by Perez’s vehicle, which was unlikely, as Gullett testified that she never honked while Perez was allegedly reversing into her car, even though Gullett would have had ample time to do so.