On Sept. 10, 2011, plaintiff Caesar Illescas, 53, a pizza delivery driver, was traveling on Telegraph Road in Whittier when he crossed the intersection with Mills Avenue and came to a stop for traffic in front of him. While stopped, Illescas was rear-ended by a sport utility vehicle operated by Daniel Segovia. Illescas claimed to his lower back, right knee, and left shoulder. Illescas sued Daniel Segovia and the owner of the SUV, Daniela Segovia. Illescas, who is only fluent in Spanish, testified, through the use of a translator, that Mr. Segovia was negligent in the operation of the SUV and that Ms. Segovia was vicariously liable for Mr. Segovia’s actions. Mr. Segovia admitted liability for the accident, but claimed the collision occurred at only 5 mph. Defense counsel presented photographs showing minor damage to Illescas’ vehicle and the defense’s accident reconstruction expert opined that the delta-v, or change in velocity, due to the impact was only 4 to 7 mph., Eleven days after the accident, Illescas went to an orthopedist with complaints of pain to his lower back, right knee, and left shoulder. He was diagnosed with soft-tissue strains and sprains and treated with physical therapy. Illescas claimed that when his condition did not improve, he underwent MRIs, which revealed a torn rotator cuff of the left shoulder, a torn meniscus of the right knee, and 1- to 2-millimeter lumbar disc bulges. He initially received epidural injections to his lower back, but ultimately underwent decompression surgery in August 2012. At trial, Illescas testified that he made a full recovery from his following the surgeries and injections, but that he will eventually require a total right knee replacement. Thus, he sought recovery of $315,000 in past medical costs (post-Howell), $80,000 in future medical costs (for the knee replacement), and approximately $850,000 to $1.3 million for his past and future pain and suffering. Defense counsel disputed the nature and extent of Illescas’ alleged damages. Counsel argued that the mechanism of injury from the subject rear-end impact would not cause Illescas’ knee to strike the dash, or cause Illescas’ shoulder and lumbar spine to become loaded. Thus, counsel argued that Illescas’ alleged torn rotator cuff, torn meniscus, and bulging lumbar discs were unrelated to the subject accident, as were the eventual surgeries. Defense counsel contended that even if Illescas’ pre-existing condition was aggravated by the accident, the alleged medical bills for treatment/surgeries on a lien were clearly excessive. Thus, defense counsel argued that the jury should only award Illescas $15,000 in total damages.