On Oct. 20, 2008, plaintiff Jeff Burkett, 39, a delivery driver for Bedrosians Tile & Marble, drove to Ace Tile to deliver three slabs of granite. When he arrived, the only Ace Tile employee was Alford Overacker, who called his boss, Alfred Keathley, to advise of the delivery. Keathley permitted Overacker to operate a forklift to unload the slabs with the assistance of Burkett. Ace Tile was located on the premises of Keathley’s father-in-law’s business, Simonian Farms, and was permitted use of the Simonian Farms’ forklifts. George Lovett was another tile contractor who had actually purchased the granite from Bedrosians and had arranged for it to be delivered to Ace Tile for Ace to fabricate. In order to off-load the granite, Overacker got a forklift, attached a boom and clamp to the mast. Burkett stated it was decided that he would stand on the truck, raise his hand to the point over to the slab where Overacker needed to deliver the clamp, pull a slab out from the A-frame on his truck, and then tell Overacker to lower the clamp. Burkett further stated that he would then fasten the clamp and instruct Overacker to lift the slab. They were ultimately able to get one slab off the truck in this manner. However, in the process of removing the second slab, it started to fall on top of Burkett before the clamp was attached, causing him to jump off of the truck and fall four or five feet to the ground below. Burkett sued Alford Overacker; Alfred Keathley, individually and doing business as Ace Tile; and George Lovett, individually and doing business as George A. Lovett Tile. He also sued Kimberly Keathley, individually and doing business as Ace Tile; Bonnie Simonian, individually, doing business as Simonian Farms and as Trustee of the Simonian Family Trust; and Dennis Simonian, individually, doing business as Simonian Farms and as Trustee of the Simonian Family Trust. Burkett alleged that Overacker was negligent in the operation of the forklift. He also alleged that the other defendants were negligent in the training of Overacker and that they were vicariously liable for his actions. Prior to trial, Overacker, Lovett, Kimberly Keathley, Bonnie Simonian and the Simonian Family Trust were dismissed from the case for tactical reasons. Thus, the matter proceeded to trial only against Alfred Keathley, individually and doing business as Ace Tile, and Dennis Simonian, individually and doing business as Simonian Farms. Burkett, who had been a delivery driver for about six years, testified that he performed the procedure of removing granite slabs from his truck in the same manner as on the day in question more than a thousand times. He also testified that prior to being a delivery driver, he worked in the warehouse at Bedrosians, where he was first trained in handling slabs. Burkett claimed that as he started to pull the slab out on the day in question, he immediately felt extreme pressure and, pursuant to his training, he got out of the way. Plaintiff’s counsel contended that Overacker had never performed the operation previously and had no training in the procedure. Counsel also contended that Overacker was not a certified forklift operator and had not been trained on its use at this facility. The plaintiff’s accident reconstruction expert testified that it was possible for Burkett to have pulled the slab over on himself, as it only takes 30-pounds of pressure to move a 700-pound slab from the position of rest on the A-frame to a vertical position. The expert also testified that it was possible for the clamp to have caused the slab to go forward because the clamp weighs 50 to 60 pounds, and because the relative position of the clamp to the slab could have caused the clamp to push the slab forward if the slab moved when the handler was not expecting it to move. The reconstructionist opined that it was not necessary to have a second handler involved and that other risks could be presented by having a second handler. The expert also opined that use of a wedge by the handler would help eliminate the risk associated with pulling the slab out to allow the clamp to be positioned. Given the fact that Burkett had no prior instances of loss of control, and given that Overacker was unfamiliar with the process and not certified or experienced to operate the forklift, the expert opined that it was entirely possible the forklift operation caused or contributed to the loss of the control of the slab. Overacker and a customer claimed that it appeared that Burkett had pulled the slab over on himself on the day in question. The customer also described a bar with a clamp at either end as having been used. The defense’s safety expert testified that Burkett’s training was improper and inadequate, and that Bedrosians’ failure to provide him with a wedge and an assistant was the cause of the incident. The expert further opined that if Burkett had used a wedge and an assistant, the incident would not have occurred. In addition, the expert criticized Bedrosians’ policies and procedures., Burkett was taken from the scene via ambulance. He sustained a severely comminuted fracture of his left knee, which caused compartment syndrome that resulted in permanent nerve damage. He also suffered an injury to his left, non-dominant arm, including a comminuted greater tuberosity fracture that subsequently required a subacromial decompression and debridement of a rotator cuff tear and an anterior labral tear of the glenohumeral joint. Burkett also underwent a fasciotomy the day after the accident, reconstruction of his knee 10 days later, subsequent bone graft and reconstruction, and a shoulder repair. Burkett claimed he suffers from reflex sympathetic dystrophy, which is chronic nerve pain also known as complex regional pain syndrome, in his left leg and left arm. He alleged that he is disabled in both his left leg and left arm, and can only walk a maximum of about 100 feet at a time. As a result, Burkett uses a wheelchair and a scooter to get around. The plaintiff’s treating physician testified that Burkett would have less pain had they amputated both legs, but the neurological damage would not rule out phantom pain. Thus, the physician opined that Burkett suffers daily chronic pain in both his legs and shoulders, and is a candidate for a future total knee replacement, as well as scar revision surgery. The plaintiff’s treating psychologist testified to Burkett’s post-traumatic stress disorder and depression resulting from the chronic pain syndrome. Thus, Burkett sought recovery of damages for his past and future medical expenses, past and future loss of earnings, past and future pain and suffering, and loss of household services. His wife, Amie, presented a derivative claim seeking recovery of damages for her loss of consortium based on her husband’s . The defense’s orthopedic expert opined that Burkett was satisfied being in a wheelchair and that he did not see any evidence of the plaintiff having RSD.