On April 27, 2015, plaintiff Jesus Barragan, 57, a union-affiliated high-rise window washer, was turning into his driveway, in the city of South Gate, when his vehicle was struck on the right, rear quarter-panel by an on-duty police officer, Aaron Sosa, who was driving a marked police vehicle. Barragan claimed to his head, right knee, neck and back. Barragan sued Sosa and Sosa’s employer, the city of South Gate. Barragan alleged that Sosa was negligent in the operation of the police vehicle and that the city was vicariously liable for Sosa’s actions during the course and scope of his employment. Sosa was dismissed with prejudice prior to the commencement of trial. The city agreed that Sosa was acting within the course and scope of his employment at the time of the incident and admitted liability prior to trial., Barragan claimed he sustained traumatic brain injury due to axonal shearing, as a result of a coup contrecoup injury, which is a brain injury that occurs at the site of trauma as well as at the opposite side of the brain. He also claimed he sustained a torn meniscus in his right knee and to his neck and lower back, including facet joint and disc . Barragan was taken from the scene of the crash by ambulance and brought to a hospital. He ultimately underwent three years of treatment with neurologists and received a recommendation for arthroscopic surgery on his right knee. Barragan claimed that he suffers from persistent post-concussion syndrome and that he was placed completely off of work as a high-rise window washer because of his post-concussion symptoms. He also claimed that he requires lifetime care for his traumatic brain injury, including psychiatric treatment for depression and post-traumatic stress disorder; attendant care by an licensed vocational nurse; cervical branch blocks; pain management therapy; a sleep study; surgery for his knee; and “transportation” for the rest of his life. The cost of Barragan’s life care plan ranged from $1.7 million to $2.1 million. Barragan sought recovery of future medical expenses, past lost earnings, future lost earnings and earning capacity, and damages for his past and future pain and suffering. (He waived his claims for past medical costs and expenses.) Defense counsel disputed the full scope, nature and extent of Barragan’s alleged damages. Specifically, defense counsel disputed Barragan’s traumatic brain injury and denied that the meniscus tear of the right knee was caused by the incident. Defense counsel contended that Barragan’s life care plan cost of up to $2.1 million was excessive, unreasonable and unwarranted. Counsel also contended that Barragan sole, documented work restriction was that he could not work “at heights” due to a risk of falling, but that Barragan had the skills and was physically and mentally capable of working in other similar types of jobs. However, defense counsel did not dispute that Barragan suffered from depression as a result of the accident.