On Sept. 17, 2009, at approximately 8:45 p.m., plaintiff Karol Perrelo, a preschool teacher in her 30s, was driving south on Euclid Avenue in E. Los Angeles when she entered the intersection with Garnet Street and broadsided a vehicle operated by Moises Jimenez, who was traveling west on Garnet Street. Perrelo claimed to her right shoulder, left foot and both hands. Perrelo sued Jimenez, alleging he was negligent in the operation of his vehicle. Specifically, she claimed that since she was traveling on an uncontrolled part of the intersection and had the right of way, Jimenez caused the crash by failing to stop for a stop sign at the subject intersection. However, Perrelo claimed she never saw Jimenez before impact. Jimenez claimed that he made a full stop at the intersection, looked both ways, and then proceeded forward before being struck by Perrelo on his rear, passenger door. He alleged that the point of impact proved that he entered the intersection first. Jimenez also claimed he did not see Perrelo prior to impact since she wasn’t using her headlights. Thus, he alleged that Perrelo violated the Vehicle Code by driving with no headlights on in the heavy dark, causing the collision., Within days of the accident, Perrelo went to an urgent care facility with complaints of pain to her right, dominant shoulder and left foot. She was subsequently referred to an orthopedic surgeon, who diagnosed her with a right brachial plexus tear and a left foot fracture. Perrelo was also referred to a neurologist and diagnosed with bilateral, traumatic carpal tunnel syndrome. In addition, she claimed she suffered a possible right elbow fracture in the crash. In December 2011, Perrelo underwent a brachioplasty on her right shoulder. She also underwent chiropractic care and physical therapy intermittently during her recovery, but has since stopped all treatment. Perrelo claimed that despite surgery and other treatment, the injury to her right arm/shoulder is permanent. She claimed that as a result, she cannot lift her right arm above her head and has limited range of motion. Thus, Perrelo claimed $133,394 in damages for her past medical costs, $19,434 in damages for her past lost earnings, and $850,000 in damages for her past and future pain and suffering. Defense counsel argued that based on the force of impact, the subject accident was not a causal factor of any of Perrelo’s alleged . Specifically, defense counsel contended that Perrelo’s shoulder injury was caused by chronic use.