On June 8, 2015, plaintiff Harley Squires, 28, an electrician, was hired by C&B Tree Service, LLC to help the company’s owner, Bradford (“Bradley”) Kruck, trim a tree on a private property owned by Hadi Natouf, in Alameda. While trimming the tree, Kruck dropped a 20 to 30 pound tree limb from about 20 feet high, striking the top of Squires’ head. Squires sued Kruck, C&B Tree Service and Natouf. Squires alleged that Kruck and C&B Tree Service were negligent in the performance of the tree trimming and that Natouf was negligent for hiring Kruck, who was an unlicensed contractor. Natouf settled with Squires prior to trial. Squires claimed Kruck negligently dropped the tree limb without looking below to ensure he was not in the drop zone. Although he had worked for Kruck on a couple of jobs, Squires alleged that he was an independent contractor and that Kruck was liable for his . Kruck’s general liability insurer denied coverage on the ground that Squires was an “employee” and not covered under the policy. The insurer also refused to defend or indemnify Kruck. Kruck admitted he dropped the tree limb that injured Squires, and the matter proceeded to a bench trial to determine liability and damages., Squires sustained blunt force trauma to his head from being struck by the tree limb. He sustained a highly comminuted skull fracture involving his frontal, parietal, temporal, sphenoid, and occipital bones. He also suffered bleeding in multiple areas of his brain and lost consciousness. Squires was taken by ambulance to Highland Hospital, in Oakland, where he underwent a bifrontal decompressive craniotomy, during which part of the skull was removed to allow his swelling brain room to expand without being squeezed and which the removed skull flaps were temporarily placed into his abdomen. Three months later, the skull flaps were extracted from his abdomen and the skull was closed. Squires claimed he suffers permanent residuals, including significant cognitive deficits, seizures, debilitating headaches, and left side spasticity, which requires him to use of a cane to walk. He also claimed that he requires extensive future medical care, including 24/7 attendant care. Plaintiff’s counsel presented testimony as to the severe impact of Squires’ using 12 videotaped depositions and four live witnesses.