Spencer J. Pahlke negotiated a settlement in the amount of $920,000 on behalf of a client who visited a Solano County nightspot to celebrate with her friends where a disturbance erupted near closing time on an outdoor patio. A club security guard acting in response to the disturbance pushed his way through the crowd, knocking the plaintiff to the ground and injuring her knee. The knee developed repeated infections necessitating more than a dozen surgeries. Because neither the plaintiff nor her friends had reported the incident to the club, the defendant denied liability alleging there was no evidence of how the event actually occurred. Compromising matters further, midway through the litigation the night club’s insurance carrier filed a declaratory relief action, arguing that the conduct involved was excluded under the policy’s intentional tort exclusion. Medical expenses were less than 5% of the billed amount because all treatment was paid for by Medi-Cal. Notwithstanding these challenges, Spencer focused on general damages and the club’s dearth of policies and training in bringing the case to a successful conclusion on the eve of trial.