On May 7, 2015, plaintiff Faig Freihat, an unemployed 54 year old, was driving on Victoria Street, in Costa Mesa. As he entered the intersection with Canyon Drive, his vehicle was broadsided by a vehicle operated by Susan Leon, who was attempting to make a left onto Canyon Drive from the opposite direction on Victoria Street. While a green traffic light permitted Leon’s entrance into the intersection, she did not have a green left turn arrow. Upon impact, the air bags in Freihat’s vehicle deployed and Freihat claimed to his right shoulder, head and back. Freihat sued Susan Leon and the owner of Susan Leon’s car, Kelly Leon. Freihat alleged that Susan Leon was negligent in the operation of her vehicle and that Kelly Leon was vicariously liable for Susan Leon’s actions. The defendants admitted liability., Freihat claimed that he sustained a concussion, resulting in tinnitus and post-concussion syndrome. He also claimed that he suffered an aggravation of a prior injury to his right, dominant shoulder, resulting in a labral tear, and an aggravation of a prior lower back injury, resulting in a herniated lumbar disc at the L5-S1 level. After the crash, Freihat was placed in an ambulance and transported to Hoag Hospital Newport Beach, where he was diagnosed with a neck strain, and was treated and released. A few days later, he visited his primary care doctor with complaints of headaches, dizziness, and tinnitus, which is a ringing in the ears. Freihat claimed the tinnitus specifically resulted from the deployment of the air bags during the crash. He later saw a specialist for his alleged tinnitus and post-concussion syndrome, but received no additional treatment for those . At the end of May 2015, Freihat saw a treating knee surgeon for a prior injury unrelated to the accident. However, he also mentioned he had pain to his right, dominant shoulder, which he believed was due to the May 2015 crash. An MRI was recommended, and Freihat was diagnosed with a labral tear and shoulder impingement syndrome. As a result, he began a course of physical therapy in June 2015. At around the same time, he also began complaining of problems to his lower back, but he claimed he originally wanted to focus on repairing his shoulder and did not start treating his back pain until later. Freihat ultimately underwent arthroscopic surgery on his right shoulder in October 2015. However, during his subsequent post-surgery physical therapy, he re-injured the shoulder, suffering an open tear of his right rotator cuff. After some follow-up appointments with an orthopedist, Freihat underwent a second arthroscopic repair of his shoulder in August 2016 and had additional follow-up appointments after the second surgery. He then started treating his back pain in September 2016 and the following month, he underwent an MRI that showed a herniated lumbar disc at the L5-S1 level. Freihat then received morphine injections and a series of epidural steroid injections, the latest of which took place in 2017. Freihat admitted that he had previous to his right shoulder and lower back, but he claimed that the subject accident aggravated those . He also claimed that both his back and his shoulder were symptom-free prior to the crash and that he had never had shoulder tears before the accident. Freihat was looking for employment at the time of the crash, but he never returned to work after the accident. He also stated that he had enjoyed working on cars, but that his tinnitus made the work difficult because he could not hear what was wrong with the vehicles. He also stated that he can no longer ride his bike with his family or coach soccer. Plaintiff’s counsel contended that Freihat was a candidate for future back surgery. Freihat sought recovery of past and future medical expenses, loss of future earning capacity, and damages for his past and future pain and suffering. Defense counsel maintained that Freihat’s were pre-existing and exaggerated. Counsel specifically noted that Freihat never complained of back pain until several years after the subject crash and that a shoulder MRI, which Freihat received in August 2014, showed the same damage that was present in the post-crash MRI. The defense’s expert neurologist allegedly found no evidence of neurological impairment. The defense’s retained orthopedic surgery expert opined that the accident only caused sprains and strains to Freihat’s shoulder and that those should have resolved within eight weeks. The defense’s otolaryngology expert performed an independent medical exam and opined that Freihat had no hearing problems. The expert also opined that if the accident had caused Freihat’s tinnitus, the ear ringing would have started immediately after the crash. Defense counsel contended that Freihat’s medical records showed that he had complained about shoulder and back pain in the years prior to the accident. Counsel also pointed to a deposition Freihat gave during an unrelated workers’ compensation litigation about a prior workplace accident. During the deposition, which took place after the subject car crash, Freihat claimed that the workplace accident was the source of all of his .