On July 21, 2017, plaintiff Bhupinder Singh, 37, a truck driver, arrived at a warehouse in Capay, near Sacramento, to pick up produce. While a forklift was loading pallets of tomatoes onto Singh’s trailer, Singh went to get a better view of how the trailer was being loaded and check on the weight distribution inside the trailer. However, as he walked across the warehouse, the forklift operator, Jose Perez, ran over Singh’s right leg, crushing it. Singh sued Perez’s employer and the owner of the warehouse, Capay Inc. Singh alleged that Perez was negligent in the operation of the forklift and that Capay was liable for Perez’s actions. Plaintiff’s counsel contended that Perez failed to look back in the direction of travel when he put his forklift into reverse, causing Perez to back into Singh. Counsel argued that by not looking backward, Perez violated state, industry and Capay’s own rules regarding the safe operation of a forklift, which require operators to always look in the direction of travel to make sure everything is clear and there are no pedestrians in the way. Plaintiff’s counsel further argued that Perez failed to designate a safe area for truck drivers to stand during the loading process. Defense counsel contended that Singh was specifically instructed to stay out of the active forklift operating zone and to stand in the corner. Counsel also pointed out that Singh, by his own admission, did nothing to get the attention of Perez to alert Perez that he was going to walk across the active loading zone. Thus, defense counsel argued that Singh was the sole cause of the accident., Singh sustained a crush injury to his right leg. He was taken by ambulance to Kaiser Permanente Vacaville Medical Center, in Vacaville, where a surgeon performed an emergency “open” amputation that evening. Two days later, a “definitive” below-the-knee leg amputation was performed. Singh was discharged home after 11 days in the hospital. Singh claimed that he could not return to work as a truck driver. Instead, he found employment as a dispatcher, but he was making less money than he was previously making as a truck driver. Plaintiff’s counsel contended that Singh would eventually require one major revision surgery and four minor revisions to his residual limb. With respect to his prosthetic leg needs, both sides agreed that Singh would need a daily use leg, an aquatic leg, and an activity leg for exercise. However, plaintiff’s counsel proffered that Singh also required a fourth, back-up, daily use leg, and a microprocessor foot and ankle for the daily use leg. The parties stipulated that Singh’s past medical costs totaled $126,401.71, which was the amount paid by MediCal. While he did not seek recovery for his past loss of earnings, he did seek recovery of economic damages for his future loss of earning capacity. He also sought recovery of noneconomic damages for his past and future pain and suffering. Singh’s wife, Reena Rani, presented a derivative claim, seeking recovery for her loss of consortium. Defense counsel disagreed with Singh’s alleged future medical expenses and need for the alleged future surgeries. Counsel argued that Singh made a great recovery and that there was no need for a major surgery. Defense counsel also argued that the aquatic or activity leg could serve as a backup leg, if one was needed, and that a microprocessor foot and ankle for the daily use leg was contraindicated.