Roger

FACTS

1. The Background and Circumstances of Plaintiff’s Injury After the 1996 automobile accident that paralyzed him from the waist down, plaintiff tried to live as normal a life as possible, an effort encouraged by his doctors, who put no limitations on his activities. He lived at home with his mother and a caregiver, drove his own van, engaged in woodworking and van maintenance activities and other activities. His wife and children lived in the State of Washington, and the family planned an outing to Magic Mountain during one of their trips to see plaintiff in October 2010. Plaintiff’s paraplegia caused other medical complications in his life. These included a history of deep vein thrombosis (blood clotting in the veins of his lower

2 extremities). Plaintiff took anti-coagulation (blood-thinning) medication to reduce the risk of blood clots, but had been taken off that medication about a week or so before the trip to Magic Mountain. (In the several instances when plaintiff was treated for blood clots in his veins, he was not taking the blood-thinning medication.) Other medical problems included bed sores; chronic pain in his right groin; high blood pressure controlled by…