Yunuen Garcia, as Administrator for Estate of Sugey A. Garcia Chavez v. Doe White Trucking Company

BACKGROUND

21 Plaintiff Yunuen Garcia is the administrator for the Estate of Sugey A. Garcia Chavez. Dkt. 22 No. 31-2 at 2 (SAC)1. On July 20, 2016, plaintiff’s sister, Sugey A. Garcia Chavez, was traveling 23 northbound on US Highway 101 near Willits, in Mendocino County, California, when the brake 24 drum of a tractor-trailer fell and “[struck] the roadway surface directly ahead” of Ms. Garcia Chavez. 25 Id. at 6 (SAC). Ms. Garcia Chavez was unable to avoid the brake assembly in the roadway and a 26 27 1 large portion of the brake assembly collided with Ms. Garcia Chavez. Id.; see also Dkt. No. 31-3 at 2 17 (Ex. B, Krankemann Decl. – Highway Patrol Report). The truck-trailer continued traveling 3 northbound on the highway. Dkt. No. 31-3 at 17 (Ex. B, Krankemann Decl. – Highway Patrol 4 Report). After the accident, Ms. Garcia Chavez was found unresponsive and she later succumbed 5 to fatal injuries. Id. Despite descriptions by multiple witnesses, as well as a review of all video 6 footage of the collision, the identity of the tractor-trailer is unknown. Id. at 18. 7 On July 18, 2018, plaintiff filed a complaint in the Superior Court of California…