On Aug. 9, 2012, applicant Augusto Puertas, 57, a merchandising supervisor for Home Depot, was working in the course and scope of his employment at a Home Depot warehouse in Fontana when fencing fell off a cart and struck his chest region. As a result, Puertas was thrown backward onto the cement floor, causing his head to become pinned between two pieces of fencing. Puertas filed a workers’ compensation claim against his employer, The Home Depot. Puertas brought the claim against Home Depot in an attempt to collect workers’ compensation benefits from the company’s workers’ compensation carrier, Liberty Mutual Insurance Co., Puertas struck the back of his head (the occipital region) on the cement floor and lost consciousness. He sustained a traumatic brain injury, as well as trauma to his back and left shoulder. He was subsequently taken by ambulance to Kaiser Permanente Fontana Medical Center, in Fontana, and discharged later that the same day. Puertas was diagnosed with severe depression and anxiety with suicidal ideation as a result of the traumatic brain injury. He also claimed he suffers from psychological problems and problems with his sleep. He also continues to have severe cognitive issues with memory and word-finding, and continues to complain of headaches, dizziness, and shakiness. In addition, Puertas claimed that he suffers from executive dysfunction, chronic pain in the form of headaches, impaired speed, slowed processing, and vision impairment. He also reportedly attempted suicide three times since the date of the accident. The medical/legal evaluators in this matter opined that Puertas would benefit from continued multidisciplinary rehabilitation at Casa Colina, in Pomona. They also opined that Puertas requires home health care on a psychiatric basis to manage his medication, and to address the ongoing psychiatric and behavioral issues. They further opined that Puertas requires additional hours of home healthcare to assist him with activities of daily living from a neuropsychological standpoint. Puertas’ prior counsel made a demand for settlement of $75,000. However, two months later, in February 2016, new counsel was substituted into the matter and performed extensive further discovery that allegedly bolstered Puertas’ position that he was unable to compete in the open labor market. Defense counsel accepted the alleged , but disputed the nature and extent of those .