On Jan. 6, 2017, plaintiff Anthony Davis, 45, a handyman, was driving on Sunset Boulevard, in Los Angeles. His car’s rear end was struck by a trailing car that was being driven by Tyler Harano. Davis’ vehicle was propelled forward, and it struck the rear end of a preceding vehicle. That vehicle was propelled forward, and it struck the rear end of another vehicle. Davis claimed that he suffered of his neck and a shoulder. Davis sued Harano and the owners of Harano’s vehicle, Charlane Harano and Randall Harano. Davis alleged that Tyler Harano was negligent in the operation of his vehicle and that Charlane Harano and Randall Harano were vicariously liable for Tyler Harano’s actions. Charlane Harano and Randall Harano were dismissed, and Tyler Harano’s counsel conceded liability. The trial addressed damages., Davis claimed that he sustained a cervical injury and a tear of his left shoulder’s superior glenoid labrum from anterior to posterior (a SLAP tear). Although he did not have any complaints of pain, discomfort or problems at the accident scene, he sought medical treatment five days later. He underwent chiropractic treatment and received five facet-block injections to the cervical spine, which were administered by orthopedist Dr. Farshid Hekmatt. Davis also underwent a shoulder surgery, which consisted of a SLAP repair, which was performed by another orthopedic surgeon, Hekmatt ‘s brother. Davis also underwent a C6-7 foraminotomy and a microdiscectomy on his cervical spine, which was performed by his treating neurosurgery expert. Davis’ expert neurosurgeon opined that Davis will eventually need a cervical rhizotomy, additional pain management injections and cervical fusion. Davis sought recovery of $1.6 million in total damages, including $305,983.95 in total medical specials. Defense counsel noted that the damage to Davis’ vehicle amounted to $4,159.33 and that the damage to Tyler Harano’s vehicle amounted to $4,792.52. Counsel contended that although Davis’ biomechanical expert testified that the delta-V was between 8 and 12 mph, the expert did not perform any calculations and testified that his opinion was simply based upon his review of the photographs and repair estimates of the vehicles. Defense counsel noted that Davis’ biomechanical expert also testified that he assumed that Davis was gripping the steering wheel tightly, causing the SLAP tear during the accident, but that on cross-examination, Davis admitted that he was not gripping the steering wheel tightly. Counsel also noted that Davis was in an automobile accident on Jan. 23, 2016, just one year before the subject accident, and that Davis sustained to his cervical spine during the 2016 accident, resulting in numbness and tingling for which Davis received chiropractic treatment. Counsel further noted that Davis’ last visit with the chiropractor for sustained in the 2016 accident was in April 2016, just nine months before the subject accident. Defense counsel contended that at the time of his last chiropractic treatment in 2016, Davis claimed that he continued to have complaints of cervical pain and that his cervical injury had not resolved. In addition, counsel noted that Davis had a history of diabetes and that Davis admitted that his job was physically intensive. However, defense counsel pointed out that Davis admitted he was able to remodel an entire bathroom without any help in August 2017, just eight months after the subject accident, while in the middle of his course of treatment. Defense counsel argued that Davis never had any radicular complaints throughout the course of his 52 chiropractic treatments and that all of Davis’ medical treatments were attorney-referred and on a lien. Counsel contended that Davis’ own attorney referred to Davis to seek treatment with Hekmatt and Hekmatt’s brother as a “collaboration.” Counsel also contended that Davis’ pain level throughout the chiropractic treatment was never more than 3 out 10 and that Davis reported to his chiropractor that his pain level was only a 1 out of 10 a day before he received his first facet-block injection. As a result, defense counsel argued that Davis’ alleged complaints to Hekmatt were inconsistent with his complaints to his treating chiropractor as he treated with each medical provider concurrently. Counsel contended that on Davis’ first visit to Hekmatt, the examination was normal and that despite the benign examination, Hekmatt ordered an unnecessary MRI of the neck, which allegedly showed nothing but long-standing degenerative changes that were not made worse by the subject accident. Counsel also contended that Davis treated with Hekmatt’s brother, who recommended that Davis undergo a set of three epidural injections, but, instead, Hekmatt performed five facet-block injections and never provided the epidural injections. In addition, defense counsel noted that Davis’ facet blocks were all performed at Beverly Hills Center for Arthroscopic and Outpatient Surgery, a Los Angeles surgery center owned by Hekmatt and Hekmatt’s brother, and that the anesthesiologist for the facet blocks was Hekmatt’s sister. Defense counsel maintained that Davis had several gaps in treatment, ranging from three months to 10 months, and that Davis would return to Hekmatt for an injection after the gaps in treatment without an interim examination. Counsel also maintained that Hekmatt’s brother also recommended a left shoulder surgery despite a normal examination of the shoulder and that Hekmatt’s brother referred Davis for an MRI of the left shoulder, which allegedly showed long-standing, degenerative changes that were not made worse by the accident. Defense counsel contended that even though Davis’ shoulder condition was not caused or aggravated by the accident, Davis underwent shoulder surgery at Beverly Hills Center for Arthroscopic and Outpatient Surgery, during which Hekmatt acted as the assistant surgeon, Hekmatt’s brother performed the procedure, and Hekmatt’s sister acted as the anesthesiologist. In addition, counsel noted that Davis underwent post-surgical therapy at Davis’ expert’s medical office, Hekmat Orthopedics. However, defense counsel contended that there were no records documenting the physical therapy and that only bills were produced for the therapy. On cross-examination, Hekmatt admitted that he did not perform interim examinations after Davis’ gaps in treatment and that all of Davis’ injections lasted only five minutes. The expert also admitted that Davis was charged approximately $10,000 for each five-minute injection and that there were no records to support the billing for Davis’ post-surgical therapy. In addition, Davis’ expert admitted that Davis never told him about the 2016 accident. Davis’ billing expert admitted during cross-examination that he did not review any of Davis’ records and that he only reviewed Davis’ bills. The expert also testified that Davis’ medical bills were too high, so he cut them by $70,000, and admitted that he was previously disqualified as an expert. Defense counsel contended that after the shoulder surgery, Davis was referred by his attorneys to Davis’ expert neurosurgeon, whom Davis saw two years after the subject accident, and that during his initial visit, Davis completed a patient questionnaire that included a pain diagram, which Davis circled as only having pain in the neck, and did not identify any radicular pain, numbness or tingling. Defense counsel contended that despite the normal examination, Davis’ lack of radicular complaints and the lack of conservative care, Davis’ expert neurosurgeon recommended a foraminotomy during Davis’ first visit, which was performed on the C6-7 level at Starpoint Surgery Center. Counsel also contended that, before undergoing the foraminotomy, Davis’ expert neurosurgeon referred Davis for a second unnecessary MRI of the neck, which was conducted just one year after Davis’ first MRI, and that the second MRI was unnecessary and no different from the initial MRI. On cross-examination, Davis’ expert neurosurgeon admitted that Davis’ case was the third trial he had testified at in three weeks that had the defense firm involved. He also admitted that in two of those trials, he recommended the patient undergo spinal surgery on the first visit. Davis’ expert neurosurgeon further testified that Davis never told him about the 2016 accident and that he never reviewed records pertaining to the 2016 accident. In addition, the expert acknowledged that Davis’ pain diagram did not identify any radicular complaints and that, despite that finding, he wrote in his report that Davis had radicular complaints to the left, upper extremity. The defense’s expert orthopedist testified that he examined Davis and reviewed all of Davis’ prior and subsequent records. He opined that Davis did not have any radicular complaints and that his examination of Davis was normal. He also opined that when Davis was released from treatment in April 2016, following treatment for prior neck complaints, Davis’ condition had not resolved. As a result, the defense expert opined that the left shoulder surgery, facet-block injections and C6-7 foraminotomy were all unreasonable and unnecessary. The expert further opined that Davis is severely diabetic, that the findings regarding the shoulder were consistent with diabetic adhesive capsulitis and that the facet injections were not performed properly because they consisted of diagnostic and therapeutic modalities concurrently. According to the defense’s expert orthopedist, if Davis sustained any at all, it was a neck strain and that Davis did not need any future treatment. The defense’s neuroradiology expert opined that the MRIs of Davis’ cervical spine and left shoulder showed long-standing, degenerative changes that were not made worse by the accident. The defense’s billing expert testified that she looked at Davis’ medical records and bills in their entirety, and testified that, assuming Davis’ medical treatments were reasonable and necessary, she calculated the reasonable value of Davis’ bills to be $137,000, approximately $100,000 less than what Davis’ billing expert opined. The defense’s billing expert also opined that the reasonable value for Davis’ future treatment, assuming it was necessary, was $100,000, which was a quarter of what Davis’ expert opined. Defense counsel asked the jury to award Davis nothing. However, counsel argued that if the jury determined that Harano’s conduct was a substantial factor in causing Davis’ harm, it should award Davis only for his chiropractic treatment and one MRI, which would have totaled $7,500. In response, plaintiff’s counsel contended that the defense’s expert orthopedist admitted that Harano’s negligence caused Davis’ . As a result, plaintiff’s counsel moved for a directed verdict on the issue of causation, but it was denied.