On April 7, 2011 plaintiff Louis Mocettini, 54, a truck driver employed by Reliable Trucking, was driving a T-800 model tractor-trailer manufactured by Kenworth Truck Co., a truck-manufacturing division of PACCAR Inc., a Washington-based corporation, in Fairfield, Calf. After stopping, Mocettini was attempting to dismount the cab of the truck when he fell and injured his head. Mocettini sued Kenworth, claiming Kenworth was liable for the truck’s defective design and lack of proper warnings. Plaintiff’s counsel maintained that Mocettini fell when the upper half of the grab handle used when mounting and dismounting the cab rotated while he was holding it. Counsel argued that the handle was defectively designed with mounting screws that failed to reliably attach the bar to the cab. Plaintiff’s counsel also argued that the truck did not come with any warnings about the screws in the bar requiring any monitoring or maintenance. The plaintiff’s product design expert testified that the design of the truck where the handle was fitted into a bracket secured to the side of the cab was less safe than securing the bar to the cab directly. The plaintiff’s trucking industry expert testified that Mocettini, and Mocettini’s employer, Reliable Trucking, followed all applicable industry safety standards. Defense counsel contended that the bar came loose due to poor maintenance after its purchase. Counsel also contended that while the truck’s documentation did not include any specific instructions regarding grab-bar maintenance, such maintenance is standard procedure in the trucking industry. Defense counsel argued that one of the mounting screws was noted to have been missing during the truck’s last post-fall inspection in 2013 and that markings on the bar indicated that it had come loose at least once before, but that Reliable Trucking had failed to take measures to correct the defect properly. Counsel further argued that following the last time the bar came loose, someone had repaired it by driving a screw through the bar and into the side of the cab, but that the screw had sheered in half and failed to prevent Mocettini’s fall. The defense’s accident reconstruction expert testified that Mocettini failed to keep three points of contact with the cab at all times, as called for by standard industry safety procedures, and that if Mocettini had done so, he would not have fallen. The defense’s product design and safety expert testified that the plaintiff’s proposed design would not have made the product safer., Mocettini was transported by ambulance to an emergency room. He claimed he sustained a concussion and a traumatic brain injury. Mocettini subsequently underwent one year of cognitive therapy. Mocettini claimed his injury left him with permanent memory impairment, difficulties with focus and concentration, and difficulties with anger management. The plaintiff’s vocational rehabilitation expert testified that Mocettini has been unable to work since the fall and that Mocettini is unlikely to return to work in the future. The plaintiff’s economic expert opined that Mocettini’s past and future income losses totaled between $170,824 and $232,500. Thus, Mocettini sought recovery of $2,474,148 in total damages for his past medical expenses (including $52,485 in stipulated expenses for cognitive therapy), past and future loss of income, and past and future non-economic damages. Acting as intervening claimants, Reliable Trucking sought $66,176 for post-fall salary continuation benefits and Reliable Trucking’s workers’ compensation carrier sought recovery of a $129,294 lien. Defense counsel argued that Mocettini had fully recovered from his head injury. Counsel also disputed Mocettini’s alleged psychological complaints and the amount of lost wages sought. The defense’s neuropsychology expert opined that Mocettini had fully recovered from his injury. The defense’s psychiatric expert opined that the cognitive symptoms displayed in Mocettini’s most recent evaluation could be attributed to depression, which Mocettini developed due to events unrelated to his fall, including his mom moving out of his home and both of his parents developing chronic illnesses. The defense’s vocational rehabilitation expert opined that Mocettini could return to work and the defense’s economics expert opined that Mocettini’s wage losses totaled only $75,000.