On Dec.8, 2010, plaintiff Luis Gutierrez, 31, a foreman on a chicken ranch outside Hanford, was operating a two-year-old Kubota tractor and pulling behind him a 2010 Poultry House Flame Sanitizer — essentially a large sled holding a 124-gallon propane tank and producing ground-level flames at 2000 degrees Fahrenheit. Driving through a chicken house, Gutierrez heard a hissing sound behind him and looked over his right shoulder. He saw a white-liquid mist. The mist quickly erupted into flame, so he hit the red (master) control switch beside him to turn off the machine. Instead, the flames shot up to the ceiling, and suddenly he was on fire. He ran from the chicken house and jumped into a large puddle to extinguish the flames. He sustained burns to 40 percent of his body. Gutierrez sued the flame sanitizer’s designer and manufacturer, Flame Engineering Inc., and the company that assembled it, Heritage Operating, L.P. (d/b/a/ Coast Gas and Amerigas Propane, L.P.). (Amerigas Propane was named and included as the successor in interest, by way of a corporate acquisition after the fire occurred, to Coast Gas; it did not train, supervise, or have control over Coast Gas or the employee who performed the installation work.) Gutierrez contended there were design defects in the flame sanitizer and negligence in the assembly. The flame sanitizer employs both vapor propane and liquid propane to power six large burners designed to burn chicken waste in the soil, thereby sanitizing chicken houses. It had been delivered to the Hanford ranch in March 2010, nine months before the fire, and had been used by Gutierrez 10 times before the fire. The parties largely agreed that a large fire occurred and injured Gutierrez; there was disagreement regarding the cause. Gutierrez’ counsel contended that a section of pipe broke off from the liquid propane valve, causing a significant amount of propane to flow out toward the tractor, in front of the sanitizer. His counsel argued that the fire was caused by a catastrophic failure of the propane system, at the location of a known failure. The hissing sound heard by Gutierrez came from a partial crack in the liquid valve, caused by corrosion fatigue in the brass fitting, which was later found to have broken there. Liquid propane was released under high pressure from the crack up toward the chicken-house ceiling. Due to convection patterns, the liquid propane fell toward the sanitizer burners and was ignited, causing a large fireball, which engulfed Gutierrez. The propane fire quickly spread to the tractor, igniting the diesel fuel and other flammable liquids, such that both sanitizer and tractor were largely consumed. Counsel also asserted that the master control switch was improperly located, at the solenoid above the defective valve, and did not shut off the propane. The defendants jointly designated their liability experts, including two fire cause and origin experts. Their position was that Gutierrez’ testimony did not support the claim that the fire began on top of the Flame Sanitizer. They stated that the source of the leak was most likely from a hydraulic fluid line under the tractor, and that the piping did not crack, but was broken at some point due to falling debris or some other traumatic blow. There was no crack in any liquid valve. They also contended the master control valve’s location made very little difference in the volume of propane. The brass fitting that failed was called for in the parts manual supplied by Flame Engineering and it was unclear if the gas company used a different brass fitting. In any event, brass should not be used in the environment of chicken farms because it is subject to corrosion., Gutierrez was taken to Community Regional Medical Center. He sustained burns to 40 percent of his body. He was emergently hospitalized from the date of the accident, Dec. 8, 2010, through Jan. 18, 2011. He was off work from the date of incident to April 15, 2012, and he went back to a modified job. He wears protective lotion on his face and hands with a large hat. He has daily constant pain in his hands and his back and his thighs. He takes medication for the pain and has severe limitations with his hands and significant bilateral weakness in his grip strength. He has documented post-traumatic stress disorder along with a depressive disorder and an anxiety disorder. His wife, Maria Arroyo, who joined suit on a claim of loss of consortium, documented multiple changes in her husband since the burn . A National Union Fire Insurance Co. lien was $455,336.75. Plaintiff’s life-care plan had a present-value computation of $487,773. The defense had a life care plan which was never shared with the plaintiff, and plaintiffs’ counsel chose not to depose any of the damage experts designated by the defense.