This action involved an car vs car accident, wherein the Defendant negligently
crossed through a stop sign on Olympic Boulevard and broadsided Plaintiff’s vehicle who
was traveling eastbound on Olympic Boulevard. As a result of the collision, Plaintiff’s
vehicle was pushed into the sidewalk striking a pole and causing the airbag to be deployed.

 Despite the fact that Plaintiff was wearing her seat belt, the severity of the impact
and deployment of the airbag caused her to lose consciousness and to sustain severe
injuries including but not limited to a fracture of her C2 vertebrae.

The reporting officer found Defendant to have been the cause of the accident by
violating California Vehicle Code, §218029(a) for failing to yield the right of way to Plaintiff.
The reporting officer also noted that Plaintiff’s vehicle had sustained major damage and
to be undriveable. Plaintiff’s vehicle was declared a total loss.

At the time of the accident, Defendant was within the course and scope of
employment.

As a result of the accident Plaintiff sustained severe injuries requiring neck surgery
at the C2 level as well as a subsequent throat surgery which had occurred as result of the
intubation from Plaintiff’s C2 cervical surgery. Additionally, Plaintiff was diagnosed as a
surgical candidate for shoulder surgery. The Plaintiff also suffered brain injury as
evidenced by the loss of consciousness. Plaintiff was diagnosed to have an impaired
memory which severely impacted her life not only requiring her to stop working but
requiring her to write reminders for herself. Plaintiff frequently misplaced objects and in
particular had difficulty remembering names and telephone numbers. Plaintiff also had
difficulty with concentration as well as having difficulty with multitasking and word finding.
Plaintiff also found herself to lose her train of thought in the middle of her conversations.

As a result of the injuries sustained from the accident, Plaintiff was unable to and/or
had difficulty engaging in her normal daily activities such as grocery shopping, cleaning her
house, sleeping, and working.