4564 A jury's conclusion that future medical damages were certain to occur was sufficiently supported by expert testimony that future medical treatment would be required, even though other expert testimony disagreed; in the absence of definite proof of the amount of future medical expenses that will be incurred, a jury may make a determination based on the evidence; a non-settling defendant should not receive credit for settlements made by other defendants that have not been paid and are not likely to be paid because the settling defendants are in bankruptcy; a non-settling defendant is entitled to a setoff for payments by other defendants allocated to plaintiff's economic damages, but not for payments allocated to noneconomic damages; in a product liability case, a non-settling defendant is not entitled to a setoff for payments made to plaintiff by a member of the chain of distribution of the same product if the jury made an undifferentiated award was based on negligence and strict products liability theories; cost waivers issued by settling defendants have a value that may be set off against the liability of non-settling defendants if the settling defendants would have prevailed at trial.

GARCIA v DURO DYNE (Judgement Reduction) 156 CA4 92 [See: CCP 877; CivC 1431.2; Bihun v AT&T 13 CA4 976, T/AT 4/93; DaFonte v Up-Right 2 C4 593]