After his lunch break on Nov. 30, 2014, plaintiff Paul Lewis, 35, a maintenance worker for Tesla Inc., returned to work on a preventative maintenance project on substation number 17, which included 12-kilovolt cabinets, at the Tesla plant in Fremont. While Lewis was attempting to clean a cabinet, there was an arc flash, causing him to sustain an electric shock. He claimed to his head, neck, back, and a shoulder. Lewis sued Electrolink Engineering Services Inc., which was a subcontractor at the plant that was tasked with de-energizing and re-energizing the power during testing. Plaintiff’s counsel contended that Lewis was not told when the energy would be restored and that Electrolink failed to protect individuals at the plant and use proper safety precautions. Electrolink claimed that workers were told during lunch that the energy would be restored and that Lewis was an experienced Tesla employee who routinely worked in various Tesla substations., Lewis sustained an electric shock, causing a variety of burns over 30 percent of his body. He also sustained a herniated cervical disc in his neck and a torn rotator cuff in a shoulder. In addition, he lost consciousness at the scene and suffered a traumatic brain injury. Lewis was immediately taken to a hospital, where he underwent skin graft procedures to treat the burns. He also underwent a cervical fusion. Lewis claimed that he still has chronic pain in his shoulder and back and that as a result, he will require surgery to treat his rotator cuff injury and a fusion surgery to treat his back. He also claimed that he suffers from cognitive impairments and headaches as a result of the incident and that he subsequently treats with neuropsychological help. However, Lewis claimed that he would have a hard time working again. Thus, Lewis sought recovery for his past and future medical costs, past and future loss of earnings, and past and future pain and suffering.