On Oct. 17, 2013, plaintiffs’ decedent Fernando Rivera, 52, an electrician, was working at the Lebec Cement Plant, a quarry and cement plant owned by National Cement Company of California and located eight miles southeast of Lebec, in Kern County. An electrical supervisor told Rivera to remove an air conditioning unit from service and store the electrical cable on the outside of the motor control center. As a result, Rivera climbed an 8-foot fiberglass step ladder, disconnected the electrical cable from the air conditioning unit, and started removing the air ducts. While he was standing on the ladder 6-feet from the ground, Rivera was being handed up electrical cable from a colleague who was standing on the ground. Rivera then began placing the electrical cable into a cable tray that had been installed by Electrical Systems Instrumentation Inc. However, when he began storing the electrical cable, the mounting brackets fastening the cable tray to the wall suddenly and without warning broke off from the wall. As a result, the cable tray fell and struck the step ladder, causing Rivera to fall onto the concrete ground below. His head violently struck the concrete, and he subsequently died from his the next day. The decedent’s wife, Misako Rivera, and the decedent’s children, Mariana Rivera, Victoria Rivera and Fernando Rivera Jr., sued Electrical Systems and Instrumentation Inc. Plaintiffs’ counsel asserted that Electrical Systems and Instrumentation negligently installed the cable tray by using two self-tapping screws to mount the tray on the right side that were not long enough to support it once the electrical cable was placed in the cable tray. Counsel contended that the weight of the electrical cable, and the physical loading of the cable, put additional stress on the cable tray mounts, causing both self-tapping screws on the right side mounting bracket to be pulled out of the sheet metal and the bottom screw to also be pulled out of a steel beam. Thus, plaintiffs’ counsel asserted that the mounting bracket screws separated from the sheet metal and steel beam, causing the tray to fall and strike the ladder and result in the fatal fall. Defense counsel raised an affirmative defense of the “Completed and Accepted” doctrine, whereby a contractor could not be held liable to third persons for damages arising out of negligent construction once an owner accepts the completed work of a contract. In this case, defense counsel asserted that the Lebec Cement Plant was liable for the accident and that Electrical Systems and Instrumentation should have been immunized from liability. Further, defense counsel contended that the decedent positioned the step ladder parallel to the building and was working perpendicular to the ladder, placing his body at an angle to the ladder. Thus, counsel asserted that the decedent was an experienced and well-trained employee who should have known proper ladder placement., The decedent sustained blunt force trauma to his head when it violently struck the concrete. He was subsequently transported by ambulance to Kern Medical Center, in Bakersfield, where he ultimately died on Oct. 18, 2013. He was 52 years old. The decedent was survived by his wife, Misako Rivera; his two daughters, Mariana Rivera and Victoria Rivera; and his son, Fernando Rivera Jr. The decedent’s family sought recovery of non-economic damages for the loss of love, affection, care, society, service, comfort, support, right to support, companionship, solace or moral support, expectations of future support and counseling, and other benefits and assistance that they would have received from the decedent. They also sought recovery of economic damages for their loss of the decedent’s earnings and financial support; funeral and burial expenses; hospital, medical, and professional and incidental expenses; as well as recovery of prejudgment and pre-trial interest.