In May 2014, plaintiff Dustin Hansen, 33, a ceiling installer, was working on a project at a commercial tenant improvement project located in Redwood City. Hansen was working on a 48-inch rolling scaffold in order to install acoustical ceiling tile in an office conference room. While the scaffold was in use, one of its wheels rolled into a 4-inch hole that was hidden by the newly installed carpeting. As a result, the scaffold tipped, sending Hansen four feet to the concrete floor. He sustained to his neck, back and right shoulder. Hansen sued the company that installed the carpet two days before the incident, East Bay Floorcovering Inc., and the company that had drilled the concrete hole three weeks earlier, EMT Electric Inc. Iron Construction Inc. was also initially named as a defendant, but it was ultimately dismissed from the case. Plaintiff’s counsel contended that the hole was unprotected, as there was no covering over the hole, as legally required by California’s Occupational Safety and Health Administration, and that the hole constituted a dangerous condition. Counsel also contended that instead of properly covering the drilled-out hole, it was only covered with carpeting, effectively creating a hidden trap. EMT Electric claimed that there was a cone near the defect every day. East Bay claimed that when its employees came into the subject room to install the carpet, there were no cones and that when they left the room, there were no cones., Hansen claimed he sustained sprains and strains of his neck and back, and a tear of his right shoulder’s rotator cuff. He drove home from work later that day, but then followed up with an occupational medicine specialist. Hansen initially attempted conservative physical therapy for a few months. He claimed that his neck and back issues partially resolved, but did not resolve his shoulder condition. As a result, he underwent rotator cuff repair surgery three months later, in early September 2014. Hansen claimed that although conservative care partially resolved his back and neck , he now suffers from chronic range of motion problems. He also claimed that he continues to have range of motion problems with his right shoulder, despite undergoing surgery. The plaintiff’s medical experts opined that Hansen had chronic range of motion problems in his shoulder, neck and back that precluded him from returning to his usual and customary job, as well as his normal activities of daily living. As a result, Hansen alleged that he has not been able to return to work in the same position, as a ceiling installer, and that he is now prevented from doing activities that he previously enjoyed. The defense’s orthopedic expert, who was called by plaintiff’s counsel during the plaintiff’s case-in-chief, confirmed all of Hansen’s and resultant sequelae. Thus, Hansen sought recovery of approximately $120,000 in past medical costs (based on his medical lien), and unspecified amounts for his future medical costs, past loss of wages, and future loss of wages. He also sought recovery of damages for his past and future pain and suffering.