On Sept. 20, 2000, applicant John Thai, 48, a sheet metal technician for Weatherite Service Corp, was in the course and scope of his employment when he fell off a ladder and struck his head on cement. Thai filed a workers’ compensation claim against his employer, Weatherite Service Corp., and the workers’ compensation insurance carrier, National Fire Insurance Company of Hartford, a subsidiary of Continental Casualty Co. Thai brought a claim against the respondents in an attempt to collect workers’ compensation benefits., Thai sustained blunt force trauma to his head, resulting in a traumatic brain injury. As a result, he was immediately taken to a hospital and, eventually, transferred to Casa Colina Hospital and Centers for Rehabilitation, in Pomona, where he was admitted into a long-term, inpatient, post-acute neurorehabilitation program. As a result of the traumatic brain injury, Thai suffers from a post-traumatic seizure disorder, spastic hemiparesis on the right side, behavioral issues, cognitive deficits, urinary retention, and a disconjugate gaze (or a failure of the eyes to turn together in the same direction). He also claimed that he suffers from depression and anxiety as a result of his condition. The plaintiff’s medical experts established that Thai would require lifelong care in a structured living environment or 24-hour in-home care with medical care from multiple specialists. After 15 years, Thai retained new counsel in an attempt to resolve outstanding issues regarding future medical care, and bring the case to a resolution. The respondents’ counsel denied that Thai needed to be at a neurorehabilitation facility and wanted to transfer Thai to a skilled nursing facility, which would be less costly.