On Aug. 21, 2011, plaintiff Maria Carachure, 64, was struck by a motor vehicle. Carachure was standing on a Riverside roadway’s bicycle lane, retrieving an item from a recyclables bin. She suffered mentally disabling of her head. Carachure’s step-grandson, plaintiff Matthew Barrera, 12; her granddaughter, plaintiff Mary Jane Fuentes, 3; and her son, plaintiff Gabriel Fuentes Jr., were nearby and witnessed the accident. Gabriel Fuentes and his mother’s guardian ad litem, Maria Estrada, who was acting in behalf of Maria Carachure, Mary Jane and Matthew, sued the vehicle’s driver, Celia Scott. The lawsuit alleged that Scott was negligent in the operation of her vehicle. The lawsuit further alleged that Scott’s actions constituted a negligent infliction of emotional distress. Plaintiffs’ counsel had previously sent a written settlement demand for Scott’s $15,000 insurance policy limit. The insurer denied the claim, alleging that Carachure was in violation of Vehicle Code § 21966, a pedestrian unlawfully in a bicycle lane. The insurer eventually agreed to accept the demand, but Carachure’s then counsel, Maryam Parman, of the Avrek Law Firm, claimed that the terms had not been complied with and that the insurance policy was open. As a result, the plaintiffs filed a personal injury suit against Scott. Scott raised an affirmative defense of settlement to bar her claim. , Carachure sustained catastrophic , including blunt force trauma to her hear that left her in a coma. She was taken to a hospital and eventually discharged home, but she is now in a quasi-vegetative state. Plaintiffs’ counsel claimed that the full value of Carachure’s bodily injury claim was $30 million. Matthew, Mary Jane and Fuentes claimed that they each suffer from emotional distress as a result of witnessing the accident.