How have courts interpreted statements by a plaintiff in a personal injury case?

People v. Allen (1976) 65 Cal.App.3d 426, 433, 135 Cal.Rptr. 276 [to be relevant under Evid. Code, 1220, "the statement must assert facts which would have a tendency in reason either (1) to prove some portion of the proponent's cause of action, or (2) to rebut some portion of the party declarant's defense"].)

[476 P.3d 274]