On April 2, 2014, plaintiff Mary Buffett, 65, a motivational speaker and writer, was leaving her unit at the Sunset-Brentwood complex, in Los Angeles. As she walked down a walkway, she slipped and fell. Buffett claimed to her left ankle and knee. Buffett sued the property managers, Sunset Brentwood Homeowners Association and Bowker & Roth Property Services Inc. Buffett alleged that the defendants failed to properly maintain the walkway, creating a dangerous condition. Buffett claimed she slipped on water and algae that had been allowed to accumulate on the walkway. The parties agreed to mediation, and the defendants stipulated to liability. Thus, the mediation addressed the issues regarding the nature and extent of Buffett’s alleged and damages., Buffett claimed she sustained a non-displaced, spiral fracture of the left ankle’s distal fibula, resulting in complex regional pain syndrome, also known as reflex sympathetic dystrophy or causalgia, a chronic pain condition. After her fall on the walkway, Buffett was transported by paramedics to St. John’s Health Center, in Santa Monica, where she was seen in the emergency room and underwent X-rays. A cast was then applied to her left ankle. The next day, Buffett followed up with an orthopedic surgeon, whom she treated with through Oct. 13, 2014. The orthopedic surgeon encouraged Buffett to continue with physical therapy in order to alleviate pain and indicated that Buffett might benefit from pain management intervention in the future. On May 17, 2014, Buffett sought treatment from a pain management physician at Alpha Pain Management, in Santa Monica. The physician noted that Buffett’s distal fibula appeared to be well-healed, but that Buffett still complained of pain. As a result, the physician indicated that Buffett would be a great candidate for a spinal cord stimulator to help treat her complex regional pain syndrome that she was experiencing at that time. Buffett next sought treatment from Lotus Physical Therapy Inc. (which was doing business as Pacific Coast Physical Therapy), in Los Angeles, on May 21, 2014. She subsequently underwent six weeks of physical therapy, two to three times per week. One week after she first presented to Lotus Physical Therapy, Buffett returned to St. John’s Health Center with complaints of headaches. However, she underwent a CT scan of the head, which a diagnostic radiologist interpreted as showing no evidence of an acute intracranial process. Buffett also saw a nephrologist that same day and related that she had a fall on April 2, 2014. Buffett’s complaints at that time consisted of pain to her left knee, ankle, and shoulder, as well as swelling to her left ankle. The nephrologist determined that the ankle swelling was due to the closed fracture of the fibula shaft. Buffett then returned to the nephrologist for a follow-up visit on June 2, 2014, as which time swelling from the fracture was again noted. On July 16, 2014, Buffett was seen by an anesthesiologist and related to him that she had a slip-and-fall incident on April 2, 2014. At the time of the visit, her current complaints consisted of neck pain and sciatica pain. Thus, the anesthesiologist diagnosed her with cervical and lumbar radiculophy with transient relief from oral steroids. Buffett then returned to the pain management physician at Alpha Pain Management on Nov. 3, 2014 for an evaluation and treatment of the alleged pain to her left foot, ankle, and leg. The doctor noted that Buffett’s pain was “unspecific.” Buffett next treated for left lower extremity problems at the Rancho Rollus Center for Physical Therapy on April 16, 2016 and April 29, 2016. Her treatment consisted of physical therapy three times per week for 12 weeks. On Aug. 4, 2016, Buffett presented to the emergency room at Cedars-Sinai Medical Center, in Los Angeles, and was seen for a psychiatric evaluation. Buffett, a motivational speaker and writer, had five speaking engagements set up in different cities in Asia in 2014, for which she was to be paid the sum of $50,000 per engagement. However, she claimed the speaking engagements all had to be cancelled due to her inability to travel from Los Angeles to Asia because of the fractured ankle. Thus, Buffett sought recovery of $250,000 in past loss of earnings and $871,599 in further loss of earnings. She also sought recovery of damages for her pain and suffering. Although Buffett claimed that her past medical costs included $1,935.52 for her treatment at St. John’s Health Center, $1,625 for services provided at Pacific Coast Physical Therapy, $863 for services rendered at Rancho Rollus Center for Physical Therapy, and $20,475.10 for all her medical treatment at Cedars-Sinai Medical Center, her medical bills were paid by her health insurance. Therefore, she did not seeking recovery of her past medical expenses. She also did not claim any future medical expenses at mediation. The defense’s pain management expert saw Buffett on July 27, 2017 and noted that Buffet’s physical examination demonstrated temperature changes, slight sensory changes, a tendency toward inversion of the left ankle, and decreased range of motion of the left ankle. The expert opined that the findings were suggestive of a partially resolved complex rational pain syndrome. He also noted that Buffett had previously sustained fractures to the left knee in 2008 and left ankle in 2012. Buffett reported to the expert that she had recovered from those with only occasional swelling and pain. However, the defense’s expert noted that 2.5 months before the April 2014 incident, Buffett underwent more ankle and sciatic nerve blocks performed. Thus, the defense’s pain management expert found that it was not clear if Buffett had elements of complex regional pain syndrome before her 2014 injury, but that, in any case, it did appear that the subject injury worsened Buffett’s prior chronic pain involving her left knee and ankle areas. Overall, the expert found that Buffett made good progress with conservative care and was returning to her usual work and that although Buffett continues to complain of moderate levels of pain, objective signs of complex regional pain syndrome have resolved with the exception of temperature asymmetry in her lower legs. Thus, the defense’s pain management expert opined that Buffett’s current treatment plan with oral Ketamine, occasional Nucynta, and Nortripyline were appropriate and that he anticipated that Buffett will continue to need the Ketamine and Nucynta on a gradually decreasing basis for the next three years. However, the expert opined that Buffett should continue using low doses of Nortriptyline for life. In addition, the expert opined that Buffett appeared to benefit from physical therapy and that he would recommend 24 more sessions of physical therapy over the next year, followed by 12 sessions the following year, followed by six sessions per year for the subsequent five years. The defense’s expert orthopedic surgeon performed an independent medical examination on Buffett on Aug. 9, 2017. At that time, Buffett complained of pain to her right shoulder, back, left hip, left knee, left lower leg, and left ankle, but related that her primary complaint was pain to the subject left ankle, which she fractured on April 2, 2014. It was noted that at the time of the defense’s expert orthopedic surgeon’s examination, Buffett had an appointment to see a pain management doctor and was still treating with her initial orthopedic surgeon. The defense’s expert orthopedic surgeon examined Buffett’s cervical spine, shoulder, lumbar spine, knees, and ankles, as well was reviewed a series of X-rays taken before the subject incident. He noted that Buffett had a history of similar types of ankle fractures and that she received appropriate treatment with the use of a cast, boot, and exercise rehabilitation programs. Thus, the defense’s expert orthopedic surgeon indicated that the treatment performed by Buffett’s initial, treating orthopedic surgeon was appropriate. The defense’s expert orthopedic surgeon also opined that Buffett’s subject fracture has united and that there is only a “slight loss of motion” regarding her ankle. He further recommended that Buffett undergo continue with a home exercise program, undergo continued strengthening, use proper shoe wear, and avoid aggravated activities. He concluded by stating that no other orthopedic intervention was recommended or anticipated. In response, plaintiff’s counsel noted that, as required by C.C.P. § 2032.610, the examining doctor must set forth the current complaint, history, physical examination, diagnosis, and prognosis. However, plaintiff’s counsel contended that the defense’s expert orthopedic surgeon did not set forth in his report a diagnosis or prognosis of the that Buffett sustained in the subject incident. Rather, the expert had an open-ended category entitled “Discussion,” which did not comply with the statute.