On Oct. 21, 2016, plaintiff Andrew Tanoos, 28, a recovering drug addict, was a client at Tarzana Treatment Centers Inc., a residential treatment facility in Tarzana, where he was assigned the top of a bunk bed that did not have a safety railing. That night, he fell off the bunk bed and sustained to his neck and back. Tanoos sued Tarzana Treatment Centers Inc. Tanoos alleged that the bunk bed constituted a dangerous condition and that Tarzana Treatment Centers was negligent in failing to address the dangerous condition. Tanoos claimed that the center was negligent for assigning him a bunk bed that did not have a safety railing. Defense counsel initially contended that there were no laws regarding the requirement of a safety railing on a bunk bed and that Tanoos would have fallen anyway because he was sitting up in the bunk bed when he fell down. The defense’s safety expert also opined, during depositions, that there was no need for safety railings on bunk beds. However, Tarzana Treatment Centers ultimately admitted liability prior to trial., Tanoos sustained a cervical fracture of the C7 vertebra, and compression fractures of the thoracic spine at T4 and T5. He also sustained protruding cervical discs at the C2-3, C4-5 and C5-6 levels. Tanoos was taken to a hospital, where he was placed in a halo brace. He then returned to the rehabilitation facility. Tanoos claimed that due to the location of the fractures in his neck and back, he would not be able to have surgery because of the risk of paralysis. He also claimed there was no guarantee he would be pain free after the surgeries. Tanoos’ treating pain management physician started Tanoos on the experimental, non-opioid ketamine, which Tanoos used for a year. The physician had attended a seminar on implanting spinal cord stimulators and intrathecal pain pumps, which was taught by the defense’s pain management expert, who is the renowned proponent of ketamine use for pain management to treat complex regional pain syndrome, also known as reflex sympathetic dystrophy or causalgia, a chronic pain condition. Tanoos’ treating physician opined that ketamine treatment was a miracle for Tanoos and that it was able to save Tanoos’ life, as Tanoos is still drug-free and pain-free. However, plaintiff’s counsel contended that Tanoos would need ketamine via intravenous infusion every five weeks for the rest of his life. Tanoos sought recovery of future medical costs, and damages for his past and future pain and suffering. Defense counsel contended that Tanoos’ medical costs were unreasonable, arguing that Tanoos’ ketamine sessions would be reasonable if they were $1,000 per session, instead of $10,000 per session. Counsel also contended that Tanoos was a lifelong drug addict and that ketamine is a drug of abuse. The defense’s pain management expert opined that Tanoos should not have been given ketamine because he did not have complex regional pain syndrome or neuropathic pain and that Tanoos should not continue using it.