Valdez

FACTS AND PROCEDURAL BACKGROUND

I. Facts

In January 2011, defendant’s sport-utility vehicle (SUV) rear-ended plaintiff’s truck on the I-605 freeway in “heavy,” rush-hour traffic. After the two exchanged information, plaintiff drove to a work-related appointment. Later that night, she started feeling neck pain and, a week later, began consulting a physical therapist for three or four months. More than a year later, she had rotator cuff surgery.

II. Procedural Background

A. Complaint In January 2013, plaintiff sued defendant and Iress Caguiat (Caguiat) for 1 negligence. B. In limine rulings on expert testimony Prior to trial, defendant designated two expert witnesses: (1) an engineer, as an accident reconstruction and biomechanics expert, to opine on the physics of the accident, how those forces affected plaintiff, and the “reasonableness and necessity” of plaintiff’s subsequent medical treatment; and (2) an orthopedic surgeon, as a medical expert, to

Caguiat is named in the complaint and the judgment, but is otherwise absent from the litigation. Ostensibly, Caguiat is the registered owner of the vehicle defendant was driving. Because plaintiff’s…