On May 2, 2013, plaintiff Salvador Santos, 61, a long-haul truck driver, stopped to pick up a load at a truck wash stop in Vernon, which was owned by LA Wash Rack Inc. While there, Santos found that his trailer’s air brakes were not functional. As he was working with a mechanic on the air brakes, an Ottawa Yard “Goat,” a terminal tractor operated by Sergio Ramirez, backed up into Santos, throwing him to the ground. Santos sustained to his head, face, shoulder, ankle and lower back. Santos sued Ramirez and Ramirez’s employer, LA Wash Rack Inc. Santos claimed that Ramirez was negligent in the operation of the terminal tractor and that LA Wash Rack was liable for Ramirez’s actions. Defense counsel contended that Santos was also negligent. However, plaintiff’s counsel disputed that Santos bore any negligence., Santos sustained basilar skull fractures and facial fractures, including a fractured maxillary sinus. He also sustained a torn rotator cuff, an injury to his lumbar spine, and a fractured left ankle. Santos subsequently received emergency medical treatment at LAC+USC Medical Center, in Los Angeles. He then treated his ankle fracture, and back and shoulder in Texas. Santos claimed that his future medical need consists of surgeries on his lumbar spine and rotator cuff. Thus, he sought recovery for his past and future medical expenses, and past and future pain and suffering. Defense counsel contended that Santos had a quick and full recovery, and that Santos would not require the alleged future surgeries. Thus, counsel argued that Santos was not entitled to the alleged future medical costs or future-pain-and-suffering damages.