Lewis v. Ukran (2019) 36 Cal.App.5th 886
Affirmance of $1.6mm judgment for plaintiff. The case holds as a matter of first impression, that “in a contested case, a party (typically a defendant) seeking to reduce an award of future damages to present value bears the burden of proving an appropriate method of doing so, including an appropriate discount rate. A party (typically a plaintiff) who seeks an upward adjustment of a future damages award to account for inflation bears the burden of proving an appropriate method of doing so, including an appropriate inflation rate.”
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