On Feb. 17, 2015, plaintiff Mackenzie White, 27, a salesperson for a luxury bus tour company, was driving on westbound East Katella Avenue, near Costa Mesa Freeway (State Route 55) overpass, in Orange, when she rear-ended a vehicle operated by Donald Bailey. White claimed to her head, neck and a shoulder. White sued Bailey, alleging that Bailey was negligent in the operation of his vehicle. Bailey passed away before the trial date, and the matter continued against his estate. White claimed that Bailey suddenly switched lanes in front of her, causing her to not be able to stop in time. Defense counsel admitted that Bailey switched lanes in front of White’s vehicle. However, counsel asserted that eight to 10 seconds after Bailey switched lanes White struck his vehicle. As a result, counsel asserted that White was to blame for failing to keep a proper lookout., White claimed she sustained a traumatic brain injury with residual neck and shoulder pain. She was immediately taken from the scene of the accident by her father and brought to a Kaiser Permanente hospital, where she was treated. White returned to work a few days after the accident, but then stopped working after she became pregnant. However, she claimed that she will need future treatment as a result of her brain injury, including rehabilitation and psychological counseling. White sought recovery of damages for her past and future pain and suffering. At trial, her counsel asked the jury to award White $500,000 to $1 million in non-economic damages. Defense counsel contended that White had previously suffered six to seven concussions playing soccer in high school and college. As a result, the defense’s neuropsychology expert opined that White’s deficits were pre-existing. Defense counsel further contended that records showed White had prior issues.