On Aug. 25, 2011, applicant Oscar Garcia, 38, a construction worker, was working on a scaffold in Redding when he fell approximately 20 to 25 feet to the ground below. He suffered to his head, face, back, and an arm. Garcia filed a workers’ compensation claim against his employer, Certified Coating, and the workers’ compensation carrier, American International Group Inc. (AIG). Garcia brought claims against the companies in an attempt to collect workers’ compensation benefits., Garcia claimed that he sustained an orbital fracture, closed head , and internal brain bleeding, resulting in traumatic brain injury. He also claimed pain to his back, an arm, and chest. Garcia underwent neurological rehabilitation in Escondido in an attempt to treat his condition, but Garcia alleged his employer, Certified Coating, tried to reduce the amount of treatment needed. Garcia claimed that he now resides with his sister and her family in her home, where he receives ongoing medical care. He also claimed that he will continue to require ongoing care either at a residential care facility or with other attendant care. According to Garcia’s current counsel, Certified Coating attempted to settle with Garcia for $200,000 after Garcia’s prior counsel recommended a settlement of $250,000. However, Garcia sought a second opinion with current counsel, who began representation in 2014. Garcia’s current counsel asserted that Certified Coating and its workers compensation insurer were in denial that Garcia needed any further treatment, which was exacerbated by the undervalued settlement amount by Garcia’s prior attorney. However, Garcia’s current counsel had Garcia undergo further neuropsychological testing in an attempt further develop Garcia’s medical records and prove the industrial nature of Garcia’s brain injury. Defense counsel agreed that Garcia had sustained an orbital fracture and a bruised head, but contended that Garcia otherwise seemed fine. Thus, counsel disputed Garcia’s other alleged and denied Garcia required any further care.