Bonds

FACTS AND PROCEDURAL BACKGROUND

I. Facts2

A. The accident On the evening of August 6, 2017, plaintiff was working as a Lyft driver in Santa Monica, California. While stopped at a traffic light, she was “rear ended” by another vehicle driven by Tanisha Curtis. As Curtis’s vehicle collided into plaintiff’s back bumper, plaintiff’s body “hurled forward violently,” which caused her head to rebound back and “slam[]” “hard into the headrest of [the] driver[’s] seat.” B. Plaintiff’s awareness of her injuries caused by the accident At the scene of the accident, plaintiff told Curtis that she “felt pain” in her “neck and back.” After exchanging insurance information, plaintiff “[i]mmediately” drove herself to a hospital and was treated for “whiplash, and neck and back pain.” In the weeks and months following the August 2017 collision, plaintiff suffered from “frequent headaches varying in

1 All further statutory references are to the Code of Civil Procedure unless otherwise indicated.

2 Consistent with the applicable standard of review, we draw the facts from the allegations of the operative complaint.

2 severity, nausea, lightheadedness, vision changes, and…