On Jan. 16, 2013, applicant Roger Wagner, 59, a laborer, was in the course and scope of his employment with Devco Sandblasting & Industrial Coating Inc., working on a project in Los Angeles County, when he fell approximately 15 feet from a ladder and landed on the floor below. While falling, Wagner’s feet became entangled in the ladder, causing him to fall onto his head. Wagner filed a workers’ compensation claim against his employer, Devco Sandblasting & Industrial Coating Inc., and the workers’ compensation carrier, Liberty Mutual Insurance Co. Wagner brought a claim against the respondents in an attempt to collect workers’ compensation benefits., Wagner fractured his right orbit, right clavicle, and several ribs on the right side, puncturing a lung. He also fractured the left, frontal temporoparietal area of his skull. As a result, he sustained a traumatic brain injury. Wagner was subsequently taken to Arrowhead Regional Medical Center, in Colton. Upon arrival, his neurologic status rapidly declined and he suffered a seizure, leaving him in a comatose condition. A CT of Wagner’s head revealed a large intracranial bleed, necessitating an emergency neurosurgical craniotomy and a hematoma evacuation surgery. Wagner remained in a comatose condition for approximately three months before there was any improvement in his level of consciousness. Upon gaining consciousness, it was found that Wagner suffered from a profound brain injury, resulting in severe cognitive and functional deficits. He also suffers from executive dysfunction, headaches, insomnia, erectile dysfunction, impaired mobility, depression, anxiety, tinnitus, impaired speed of information processing, vision impairment, decreased hearing acuity, and loss of libido. The applicant’s attorney was able to secure evaluation specialists in the areas of physical medicine and rehabilitation and neuropsychology. The specialists opined that Wagner was not suitable for any type of gainful employment, as his cognitive and physical limitations caused him to be a safety danger to himself and to others. The specialists further opined that as a result of his , Wagner was unable to effectively communicate verbally, learn new information, manage himself without great assistance from others, or follow instructions, rendering him incapable of competing in the open labor market. The respondents’ counsel disputed the severity of Wagner’s , and denied that Wagner was totally and permanently disabled.