On July 26, 2013, plaintiffs’ decedent Natalie Giorgi, a 13-year-old who was diagnosed with a peanut allergy nine years earlier, ate a Rice Krispies treat during a hula hoop contest on the last night of her family’s four-day vacation. Natalie and her family were at Camp Sacramento, a family camp and conference center located on Lincoln Highway, also known as U.S. Highway 50, near Lake Tahoe, in El Dorado County. The camp was run by the city of Sacramento since 1920 and was situated in the Sayles Flat area of the Eldorado National Forest, near Echo Summit. While the hula hoop contest was going on, Natalie and her parents left the main dining hall, where the competition was taking place. Natalie then told her parents that she ate a Rice Krispies treat that was prepared by the camp’s baker. For the next 20 minutes, the parents sat with Natalie, who at first appeared to be fine, but then Natalie vomited, went into anaphylactic shock, and almost immediately stopped breathing. Natalie’s father, plaintiff Louis Giorgi, a board-certified urologist and former Navy flight surgeon, kept an EpiPen, as most with food allergies do, to inject Natalie with epinephrine to combat an allergic reaction if symptoms appeared. As a result, Mr. Giorgi injected his daughter with the first pen, but Natalie did not respond. He was then able to obtain another pen from someone else at the camp and administered the second pen, but the injection failed to stop the allergic reaction. Since Natalie was suffocating, her parents took her to a nurse’s station, where Mr. Giorgi shattered a glass door to the medicine cabinet with his left elbow to access a third EpiPen. However, the dose did not work. Paramedics then arrived, but they were unable to revive Natalie, who died from anaphylactic shock in her parents’ arms. Mr. Giorgi, acting individually and on behalf of Natalie’s identical twin sister, Danielle Giorgi, and Natalie’s mother, Joanne Giorgi, sued the city of Sacramento and Friends of Camp Sacramento. Plaintiffs’ counsel contended that the Rice Krispies treat, which was prepared by the camp’s baker, contained peanut butter that had been mixed into a marshmallow filling in such a way as to be visually undetectable. Counsel also contended that it was difficult or impossible to determine that the treat contained peanut butter by taste. Natalie and her identical twin sister both had a significant peanut allergy that put them at risk for anaphylaxis. In previous years, the city was notified by way of medical information forms that Natalie, her sister, and other members of her family suffered from peanut allergies. The city had a policy that if even one camper at the camp had peanut allergies, then no food products with peanuts would be served. Plaintiffs’ counsel contended that on the night of the incident, Natalie attended the traditional dance hosted by the city on the last night of camp. The dance took place in the camp lodge, where the city served Rice Krispies treats prepared by the camp’s baker. However, counsel argued that, unbeknownst to Natalie, the baker added Reese’s Pieces, which are made of peanut butter, to some of the Rice Krispies treats, but the baker did not label the treats or provide any warning that the treats contained nuts. Counsel contended that the camp had served Rice Krispies treats on previous occasions, but that they never contained peanut butter before. Plaintiffs’ counsel contended that on the night of the incident, Natalie took a single bite of the treat, but spit it out because it tasted “funny.” Counsel maintained that as a result, Natalie’s parents carefully monitored Natalie for any symptoms of an allergic reaction that would warrant administering the EpiPen, but that Natalie remained asymptomatic for approximately 20 minutes. Counsel contended that when Natalie vomited, her father immediately administered the EpiPen and then asked others if they had EpiPens available. When someone provided him with another EpiPen, he administered it, as Natalie’s symptoms worsened. However, plaintiffs’ counsel maintained that the two EpiPens did not stop the cascade of symptoms and that as Natalie’s condition worsened, Mr. Giorgi entered the camp’s first aid station, where he saw an EpiPen inside of a glass-and-metal cabinet. While the camp nurse had been notified of the incident, she had not yet arrived on the scene. Counsel contended that when Mr. Giorgi was unable to open the cabinet, which appeared to be locked, he used his left elbow, in desperation, to shatter the glass cabinet door so that he could remove the EpiPen. Unfortunately, the glass cut a tendon in his left, dominant arm. Mr. Giorgi then administered that EpiPen, which also failed to stop the cascade of symptoms. Thus, plaintiffs’ counsel asserted that Natalie’s death was caused by the city’s negligence in adding peanut butter to the Rice Krispies treats and then serving the unlabeled treats. Counsel also asserted that Mr. Giorgi’s injury was a foreseeable consequence of the defendant’s negligence. Defense counsel contended that the camp requested filled out health history questionnaires for each family member on an annual basis to keep its information current. However, the camp did not receive health questionnaires for the Giorgi family in 2013. Defense counsel contended that as a result, the resident camp nurse was never informed that three of the Giorgi children were diagnosed with severe peanut allergies. Counsel also contended that the Giorgis were advised by two treating allergists to always carry two EpiPens for each daughter and that adult doses had been prescribed for each daughter as they matured. However, defense counsel contended that, for reasons unknown, the family only brought one, expired, junior dose EpiPen to camp. Counsel further contended that the Giorgis received information recommending that they carry epinephrine for their son, who was also believed to have severe peanut allergies. Defense counsel noted that all of the medical advice underscored the critical importance of immediate administration of epinephrine for symptoms similar to those initially reported by Natalie and that there was no adverse risk associated with immediate use of an EpiPen. Defense counsel had planned to call the two treating allergists to testify. Defense counsel maintained that, as a dessert for the final night’s teen dance, the assistant camp cook prepared frosting for a sheet of Rice Krispies treats that contained peanut products because she was unaware that anyone had anaphylactic-level peanut allergies during that session. Counsel contended that Natalie immediately reported to her parents that something tasted funny and that she felt tingling in her mouth. Thus, defense counsel asserted that the symptoms warranted immediate action of administering an adult-dose EpiPen, calling 911, and/or transporting Natalie to Barton Memorial Hospital, in South Lake Tahoe, but that Mr. Giorgi elected to administer Benadryl and monitor the situation. As she was being monitored, Natalie vomited and complained of difficulty breathing. Counsel contended that Mr. Giorgi then administered the junior dose EpiPen, rather than one with an adult dose, and began a panicked search for more epinephrine. Counsel contended that a camp staff member came upon the situation evolving on the patio outside the dance, opened the First Aid Room, put out a radio call for the camp nurse (who had retired for the night), and called 911 from the adjacent office. The camp nurse arrived within minutes, and she observed Natalie on the examination table near death and Mr. Giorgi bleeding from an elbow cut he sustained breaking the glass door of the medicine cabinet. Defense counsel asserted that the medicine door was unlocked, but that Mr. Giorgi did not understand the latch mechanism and did not ask the staff in the adjacent office for assistance. Counsel contended that after breaking the glass, Mr. Giorgi accessed and administered an adult strength EpiPen, but that it was too late., Natalie vomited, went into anaphylactic shock, and almost immediately stopped breathing. She was subsequently administered three EpiPens. The ambulance crew then employed further measures to save Natalie, but their attempts were unsuccessful. A medical evacuation helicopter also landed, but it was not utilized. Natalie ultimately died from anaphylaxis. She was 13. Natalie had never before suffered an incident resulting in anaphylaxis or other reaction due to her family keeping her and her sister from any exposure to nut products. Thus, Natalie’s parents sought recovery of wrongful death damages for the loss of their daughter, Natalie. Mr. Giorgi severed a tendon in his left, dominant arm. Mr. Giorgi claimed his orthopedic injury limited the use of his left arm and diminished his manual dexterity. He also claimed that his employer, Sutter Health, let him go as a clinical urologist because his job required him to conduct surgeries that he was no longer able to perform as a result of his injuries. Defense counsel noted that Mr. Giorgi presented a wage loss claim in excess of $20 million because he could no longer perform surgery. He was earning approximately $1 million per year at the time of his elbow injury.