On Sept. 6, 2008, at approximately 2:44 p.m., plaintiff Stacey Correia, 35, an unemployed woman who recently relocated to the Sacramento area to attend school, was a front seat passenger in a 2004 Ford Explorer operated by her husband. As they were traveling on northbound Stockton Boulevard in Sacramento, their vehicle was rear-ended by a 2008 Mercedes E350 operated by Chuyen Huu Do. Correia claimed to her neck and back. Correia sued Do for motor vehicle negligence. Correia’s husband stated in the police report that he was completely stopped in the right lane of Stockton Boulevard, behind a truck that had stopped for a car that was turning into a Wells Fargo Parking lot. He also stated in the police report that when the truck in front of him began to roll forward, he was going to start going forward, but he heard a loud brake sound behind him and then Do’s vehicle rear-ended his vehicle. Do stated in the police report that he had three family members as passengers in the vehicle that he was driving at the time of the accident. He also stated in the police report that he was not from Sacramento and was unfamiliar with the area. In addition, Do stated that when the plaintiff’s vehicle stopped, he was only about one car length behind it and that he hit his brakes, but he did not react fast enough and ultimately rear-ended the plaintiff’s vehicle. Thus, the investigating police officer concluded that Do was the sole cause of the accident. As a result, Do did not dispute liability. According to plaintiff’s counsel, the court ruled that plaintiff’s counsel was not allowed to introduce evidence or cross-examine Do about his earlier denials of liability made under oath., Correia claimed she was injured in the accident. She alleged that although both her and her husband declined an ambulance, and neither had emergency room treatment on the day of the accident, they had started to drive toward an emergency room after the crash, but then decided they did not want to wait and, instead, drove back to the hotel, where they were living. However, Correia claimed that she ultimately sought treatment with diagnostic facilities, medical doctors, chiropractors, physical therapy and massage. She alleged that her lien-based medical treatment included treatment for neck and back pain due to degenerative disc disease at L5-S1 and L4-5, and bulging lumbar and cervical discs at the L3-4 and C6-7 levels. She also alleged she treated for sciatica, migraines, nausea, depression, anger, frustration, anxiety, and arm and leg pain and numbness. Correia received seven epidural injections to her neck and back, and in 2009 and 2010, saw two spinal surgeons who both recommended neck and back surgery. As a result, she ultimately underwent a C6-7 anterior cervical discectomy and fusion in January 2012. Following the surgery, Correia claimed she was still disabled. However, she claimed the neck surgery was successful, she was doing better and she hoped to return to work following the recommended treatment for her lower back. In 2013, Correia relocated to Washington State and was seeking treatment there at the time of the trial. Correia’s medical specials, including her C6-7 anterior cervical discectomy, totaled $208,802.90. Of that amount, the C6-7 fusion surgery totaled $102,733, for which Medi-Care paid approximately $18,000 to the surgeon and hospital. As a result of Correia’s medical specials being subject to Howell reductions, the new total amounted to $94,705.03. Plaintiff’s counsel contended that all medical bills were medically reasonable and necessary due to the subject accident. Thus, plaintiff’s counsel, in his closing argument, requested that Correia be awarded $889,705.03 in total damages, including $94,705.03 for past medical costs, $100,000 for loss of earning capacity and $695,000 in non-economic damages. Defense counsel contested Correia’s alleged personal and attributed them to an undiagnosed medical condition, prior and degeneration. Thus, counsel argued that Correia’s alleged medical treatment was not caused by the collision. Defense counsel noted that the plaintiff’s doctor testified at his deposition that the Correia’s spinal condition was not caused by the accident or a trauma, but was degenerative in nature, and required only physical therapy, not surgery. Defense counsel noted that airbags did not deploy as a result of the impact and Correia sustained no cuts or bleeding, but had bruises to her chest area from the seat belt. He also noted that although the repair estimate for Do’s vehicle was $17,809.22, the repair estimate for Correia’s 2004 Ford Explorer was only $1,948.13. Plaintiff’s counsel, who took the case over from a different attorney, noted that defense counsel was allowed to cross-examine Correia about her decision to consult with an attorney before seeking medical care. However, the court ruled that plaintiff’s counsel could not argue that Correia consulted with the attorney in order to obtain guidance about her health insurance coverage, since Correia had relocated to the area one week before the accident. The court denied this argument because allowing it would require Correia to mention her insurance. Plaintiff’s counsel also noted that defense counsel was critical of the number of providers Correia saw, but the court ruled that plaintiff’s counsel could not explain that Correia changed medical providers because they took her new health insurance, while the earlier providers did not take her previous insurance. Specifically, plaintiff’s counsel was prevented from arguing that even though two spinal surgeons both recommended neck and back surgery in 2009 and 2010, neither surgeon would accept Correia’s Medi-Cal insurance and other attempts to finance the surgery were unsuccessful. Counsel also would have argued that as a result, Correia had to wait until she began receiving Social Security Insurance and Medi-Care in 2011 before she was ultimately able to undergo a C6-7 anterior cervical discectomy and fusion surgery in January 2012, which was performed by treating neurosurgeon Dr. Kawanaa Carter, who was reimbursed approximately $1,200 by Medi-Care.