How would this information provided be articulated into a trial brief submission?

Plaintiff Marla suffered injuries as a result of a collision between her car (a green Plymouth Voyager) and the one operated by Defendant Mark (a white turbo-charged, Ford Bronco). The accident occurred on January 10, 2020, at approximately 1:35 a.m., as Marla was exiting the southbound I-405 freeway at the Brookhurst Street off-ramp in Fountain Valley, California. The police report indicates (and the investigating officer will accordingly testify) that Marla, driving at 35 m.p.h., was decelerating on the offramp when she saw a blue minivan, directly ahead of her, suddenly swerve wildly to the left. In an instant, she understood why the minivan had swerveda large cardboard box was in the middle of her lane. Marla stepped on the brakes and brought the Voyager to a screeching halt in front of the box. The police report also states that the box, though Marla did not know it at the time of the incident, contained a large desktop computer. Eyewitnesses reported that it fell off the bed of a red pick-up truck which was driving on the off- ramp in front of the minivan. While the pick-up truck's owner has not yet been identified, the police know that it carried Rhode Island license plates partially marked "147 MC". The car directly behind Marla was Defendant Mark's Bronco. Mark was driving at approximately 40 m.p.h. when Marla applied the brakes. Although Mark had left 10-15 feet of room between his car and Marla's, he could not step on his brake soon enough to avoid striking Marla. The Bronco hit Marla's car from behind. The posted speed limit on the off-ramp was 40 m.p.h. Mark is an out-of-work diesel mechanic who had spent the evening with the local chapter of the Hell's Angels motorcycle group playing cards at one of the member's houses in a crime-ridden part of town. Marla spent the evening at Mario's Bar and Grill, a local restaurant, participating in a charity auction to raise funds for underprivileged children. Upon interrogation by the police, some of Marla's friends testified that Marla had been drinking before leaving and "kind of staggered" to her car. Marla suffered back injuries and was treated by various medical practitioners for over a year, with total medical expenses of $10,759.00. She was treated by a chiropractor and a physical therapist for two years, with medical expenses of $7,000.00. She incurred the rest of her medical expenses ($3,759.00.00) obtaining an evaluation from an orthopedic surgeon. Although the pain has largely subsided, Marla still experiences daily back discomfort and headaches. Marla is suing Mark for her medical costs ($10,759.00) plus her pain and suffering--continued back pain, headaches, insomnia, loss of concentration, dizziness ($50,000.00). She, therefore, seeks a total of $60,759.00. Marla has also sued, as a "DOE" Defendant, the unidentified driver of the pick-up truck. Marla's suit against Mark and the Doe Defendant is based on common law negligence and civil code 1708.

Mark claims that he should not be responsible for the accident because it resulted from Marla's actions. He also claims that other parties are either fully or partly responsible for the accident. In terms of Marla's negligence claim against him, Mark argues that Marla has not established all of the necessary elements of such a claim: 1) that he had a duty of care toward Marla; 2) that his conduct breached that duty (that a reasonably prudent person would have acted differently); 3) that his conduct was the cause of Marla's injuries; and 4) that, as a result of this conduct, Marla suffered injuries. In terms of Marla's claimed damages, Mark points out that California law provides that non-economic damages (e.g., pain and suffering) must be apportioned between all defendants in accordance with their proportion of fault. However, no such provision is made for economic damages (e.g., medical expenses, lost earnings, etc.)---each defendant found at fault is liable for the entire amount of damages. To back up his arguments relating to damages, Mark cites California Civil Code 1430, 1431.1, 1431.2, and 1432 as well as the case of Evangelatos v. Superior Court, 44 Cal.3d 1188 (1988) (particularly footnote 4 of the dissenting opinion). Mark also argues that plaintiff was treated excessively: that the normal treatment time to recover from an accident such as that suffered by Marla is six to eight weeks. Mark will present expert testimony at trial to support that claim. In response to Mark's arguments regarding her damages, she cites the case of DaFonte v. Up-Right, Inc., 2 Cal.4th 593 (1992)which she claims refutes Mark's reliance on Evangelatos.