On Oct. 29, 2011, plaintiff Sara Avetisian, an accountant in her 50s, was in an aisle of Restaurant Depot when a forklift backed into her. Avetisian sustained to her left shoulder and body. Avetisian sued Restaurant Depot. Avetisian contended that the aisle should have been blocked off and that the forklift driver should have checked behind him before moving the forklift. Defense counsel contended that the aisle was blocked off and that the operator did look behind him. Counsel noted that the forklift had a beeping mechanism that was engaged when the forklift backs up, so Avetisian should have heard the beeping and known that the forklift was backing up. Additionally, defense counsel contended that the store was a warehouse store with other forklifts, so Avetisian should have been aware of their presence. Thus, counsel argued that Avetisian was liable for the accident., Avetisian went to a Kaiser Permanente facility on the date of the accident. She claimed she suffered from tendinitis and an impingement of her left, non-dominant shoulder. She subsequently received an epidural injection of the left shoulder. Avetisian later underwent an arthroscopic synovectomy, a labral debridement and a subacromial decompression. Avetisian claimed she had problems with her shoulder before and after her surgery, causing her to be limited in her household work and be unable to carry heavy items. Avetisian did not make a wage loss claim, but sought recovery of $95,261.78 in past medical costs for various MRIs, injections and surgery. She also sought recovery of damages for her pain and suffering. Defense counsel contended that Avetisian’s left shoulder problems were pre-existing and unrelated to the accident.