On Aug. 1, 2011, at approximately 11:30 a.m., plaintiff Douglas Richards, 57, a respiratory therapist, was riding his bicycle at 24.6 mph, per his Garmin GPS device on his bicycle, on northbound Cornell Road, a two-lane blacktop with a white line for the shoulder, in Agoura. As Richards approached 3388 Cornell Road, a recreational vehicle operated by Carl Zickert, 89, attempted to make a left turn from southbound Cornell Road into the driveway of 3388 Cornell Road (where his daughter resided). As a result, Richards applied his brakes to avoid colliding with the RV, but went over the handle bars and hit the ground at the south edge of the driveway without making contact with the RV. He claimed multiple head and bodily from the accident. Richards sued Carl Zickert, as well as Jane Zickert, his wife and co-owner of the vehicle, and Todd Zickert, his son and co-owner of the vehicle. Richards alleged that Carl Zickert was negligent in the operation of the RV, and that his wife and son negligently entrusted the vehicle to Carl Zickert. The Zickerts stipulated to liability at trial, and the matter proceeded to assess damages., Richards was airlifted from the scene of the accident and brought to an emergency room. He claimed retrograde amnesia from the moment of the accident until waking up in the helicopter. He sustained a thoracic fracture at T7, a reverse major shoulder separation, and three fractures to the radial head of the right elbow along with non-union. He also sustained a jaw laceration that required 16 sutures and a left eye injury. In addition, Richards sustained abrasions to the right hand, both knees, left side of his face, and left shoulder and forearm, as well as developed a Staph infection in his left knee, requiring treatment. Richards underwent left shoulder surgery on Dec. 10, 2012, and continued to treat with medical professionals to evaluate his need for right shoulder surgery. He also treated with physical therapy. Richards claimed he still has pain and limited range of motion in his right elbow/arm and continues to receive ongoing physical therapy. He also claimed he sustained a mild traumatic brain injury with cognitive issues, including processing and word finding, and that he also suffers from post-traumatic stress disorder. Thus, he continues to receive therapy for his emotional . Since the accident, Richards has not returned to work. He claimed he was a triathlete that competed in multiple competitions, but that he is no longer able to compete due to his shoulder condition. Thus, he sought recovery of $8 million in total damages, which included $235,461 in past medical costs, $3.5 million in future lost earnings/life care plan, and an unspecified amount for his past and future pain and suffering. Defense counsel disputed the nature and extent of Richards’ alleged , as well as the reasonableness and necessity of his alleged treatment, the cost of his medical bills, and time missed from work. Specifically, defense counsel contended that Richards does not need future surgery on his right shoulder, that he suffered no brain injury, and that his emotional problems were a pre-existing condition due to family issues.