On April 29, 2010, plaintiff Janis Sanchez, 59, underwent a mitral valve repair at Scripps Mercy Hospital, during which she received heparin, as is required for surgery. The repair was performed without complications, but within 24 hours, Sanchez developed post-operative complications, including multi-system organ failure. By post-op day four, she suffered a cardiac arrest and required resuscitation. On May 4, 2010, Sanchez was critically ill and in complete renal failure. As a result, a critical care specialist started Sanchez on dialysis in early morning hours of May 5, 2010, and the nurses subsequently placed heparin into the dwells of the dialysis catheter to keep it from clotting in between dialysis treatments. Sanchez ultimately required amputations of both legs and several of her fingers. Sanchez sued the operator of Scripps Mercy Hospital, Scripps Health, and several doctors and medical offices. She alleged that the defendants were negligent in the administration of heparin and that their negligence constituted medical malpractice and medical battery. Several of the defendants were either dismissed from the case or settled prior to trial. Thus, the matter proceeded to trial against Scripps Health, doing business as Scripps Mercy Hospital, only. Sanchez claimed she developed an extremely rare condition known as heparin-induced thrombocytopenia with thrombosis (“HITT”), which caused irreversible damage to the blood vessels in her extremities. Thus, she claimed the administration of heparin led to her amputations. Sanchez’s counsel contended that the hospital and nurses were negligent in the administration of heparin during the surgery and during Sanchez’s dialysis. Counsel noted that although heparin is a medication that normally prevents clots from forming, it has the exact opposite effect in a patient with HITT, as it causes large clots (thrombosis) to form and results in a dangerous drop in the total number of platelets in the blood (thrombocytopenia). Thus, counsel contended that the two exposures to heparin caused Sanchez to develop HITT, which resulted in large clots forming in her arteries, thereby cutting off the blood supply to her extremities. Counsel for Scripps Health contended that Sanchez’s were caused by insufficient blood supply due to a combination of the vasopressors that Sanchez required to keep her alive in the post-operative period, as well as due to Sanchez’s overall hypotension as a result of being critically ill. The defense’s expert in hematology, who is recognized as the world’s leading expert on diagnosis and treatment of HITT, reviewed Sanchez’s records and opined that Sanchez did not have HITT. The expert explained that a diagnosis of HITT requires a certain clinical picture and confirmatory laboratory tests, which Sanchez had neither. The hematologist testified that, instead, Sanchez’s condition started to decline days prior to the second exposure of heparin by the nurses and that, likewise, three separate blood tests were all negative for HITT. In addition, the expert testified that Sanchez never showed any objective evidence of the type of large clots typically seen in HITT. Thus, counsel for Scripps Health argued that nothing the hospital’s nurses did, or failed to do, caused or contributed to Sanchez’s injury. Counsel contended that, instead, Sanchez’s were a result of unforeseen and unpreventable post-operative complications — such as respiratory failure, renal failure, liver failure, acidemia, and cardiac arrest — totally unrelated to the nurses’ use of heparin in the dialysis catheter dwells starting in the early morning hours of May 5, 2010., Six weeks after her April 29, 2010 surgery, Sanchez underwent double below-the-knee leg amputations, as well as amputations to several of the fingertips on her left, non-dominant hand. She claimed the amputations were due to her developing an extremely rare condition known as heparin-induced thrombocytopenia with thrombosis (“HITT”), which caused irreversible damage to the blood vessels in her extremities. Thus, plaintiff’s counsel presented a life care plan for Sanchez in the amount of $5.5 million in future economic damages. Sanchez also sought recovery of damages for her past and future non-economic damages. Her husband, George Sanchez, sought recovery of damages for his loss of consortium. Counsel for Scripps Health argued that Mrs. Sanchez did not suffer from HITT and that Mrs. Sanchez’s amputations were due to unpreventable post-operative complications, which included respiratory failure, renal failure, liver failure, acidemia, and cardiac arrest. Thus, counsel disputed Mrs. Sanchez’s alleged damages.