At approximately 2 p.m. on Nov. 2, 2010, plaintiff Ah Ning Chan, 61, a home health care aide, was walking west on Stoneman Avenue, toward the intersection with Main Street in Alhambra. As she attempted to cross Main Street, she was struck by a vehicle operated by Jack Seymoure Shapiro, who was making a left turn from eastbound Stoneman Avenue onto northbound Main Street. Chan claimed to her right knee and left big toe. Chan sued Shapiro. She alleged that the defendant was negligent in the operation of his vehicle. Specifically, Chan claimed that she had a green pedestrian light at the subject intersection and that Shapiro failed to yield the right of way to pedestrian traffic. Shapiro argued that he did not see Chan because she was not in a marked crosswalk at the time of the accident. Thus, he contended that Chan was liable for the accident., Chan sustained a fracture to the tibial plateau of her right leg, as well as a fracture of the left big toe. She was subsequently taken from the scene of the accident by ambulance and brought to an emergency room, where both fractures were casted. Chan was hospitalized for two weeks before being transferred to a nursing home for rehabilitation. After two months, she had the casts removed and followed up with out-patient physical therapy. In February 2012, Chan underwent arthroscopic surgery on her right knee to clean up a damaged meniscus. Chan claimed she now has a malunion of her right tibial plateau, which is inoperable. She alleged that as a result, she has ongoing discomfort in her right knee and can never return to work. Both the plaintiff’s and the defense’s medical experts opined that Chan is a candidate for a total knee replacement. Thus, plaintiff’s counsel contended that Chan had an insurance lien (post-Howell) of $150,000 and an additional $70,000 in out-of-pocket medical costs. Chan also sought $120,000 in damages for her loss of earnings and an unspecified amount of damages for her past and future pain and suffering. Defense counsel disputed the Howell reduction, arguing that Chan had paid nothing and had no balance owed to any medical provider. Counsel also disputed the amount of Chan’s claimed lost earnings.