On May 9, 2011, plaintiff Gloria Jones, 68, was seated in the backseat of a vehicle that was parked in front of her residence in San Mateo. The vehicle was operated by her husband, and Jones had a brace on her right knee, as she was coming back from a physical therapy appointment. Jones opened the side door of the vehicle, slid out, and placed her non-injured, left leg on the sidewalk curb while her husband put his hands around her waist to facilitate her exit. As she stepped onto the curb with her left foot, a section of the curb about the width of a brick rolled backward, causing Jones to fall backward. The top of her shoulders subsequently struck the vehicle frame door and she put her hands out to break hear fall, causing her hands to strike the side of the vehicle. About nine months later, on Feb. 16, 2012, Jones was leaving church in a different area of San Mateo. As she was walking across a planting strip area, an area between the sidewalk and the curb, she stepped into a hole, allegedly her right knee and ankle. Jones sued the city of San Mateo, which was the joint owner of both the curb in front of her residence and the planting strip area. Jones also sued the other joint owner of the planting strip area, Alfred Holmes, who owned the property in front of the strip. (The other joint owners of the curb were Jones and her husband.) Jones alleged that the defendants failed to properly maintain both the curb and the planting strip, creating dangerous conditions. Holmes ultimately settled out of the case prior to trial. Thus, the matter proceeded to trial against the city regarding both incidences. Plaintiff’s counsel noted that in 2007, four years before the May 2011 incident, Jones complained to the city about debris in her driveway from the curb. The city subsequently inspected the area and found the curb in disrepair, with the top of the curb missing and looking like raw concrete remained. Counsel contended that that for repair, the city applied a patch over the top of the curb that included THOR vinyl concrete patching and Rapid Set Cement, a quick drying concrete. The plaintiff’s architecture expert opined that the city’s 2007 repair to the sidewalk was negligent. In regard to the 2012 incident, plaintiff’s counsel claimed that a tenant notified Holmes of the hole, but that the city failed to come and repair the dangerous condition. The city’s counsel acknowledged that the city had notice of the sidewalk’s condition in 2007 and that it subsequently repaired it. However, counsel argued that both parties agreed that no notice was given to the city of any further issues with the curb, as Jones testified that she saw no problems with the curb until the May 2011 incident, when it gave way. In regard to the February 2012 incident, the city produced seven years of information showing that no one ever complained about the subject hole in the planting strip. The city’s counsel noted that Holmes testified that a tenant told him about the hole and that he made attempts to fill it in, but that neither he nor the tenant called the city to advise if of the hole. The defense’s accident reconstruction expert testified about how he went back to review the overhead photographs from Google Earth to discern whether they would reveal what would have caused the hole in the planting strip. He noted that there was a utility pole three feet from the hole, but that the pole was never moved, as confirmed by seven years of photos. He also noted that there were no plants, trees or bushes that were removed that could have created the hole and that the city had no signs removed from the area that could have created the hole either. In addition, the city claimed that it did not find any public complaints about the hole or anything near it, nor did it find any work orders for any work in the area that could have created the hole. Thus, the city’s counsel argued that the city did not have prior notice of the hole., Jones claimed that in the May 2011 incident, she sustained a rotator cuff tear in her right, dominant shoulder and an injury to her left thumb, resulting in trigger thumb, also known as stenosing tenosynovitis, a condition in which the thumb (or another finger) gets stuck in a bent position. As a result of the May 2011 incident, Mrs. Jones claimed and a left trigger thumb injury. Jones noted that she had a previous fall in February 2011, resulting in a fracture of the right tibial plateau, a fracture of the right fibula, and a sprained left thumb. During the course of physical therapy for the prior fractures, Jones complained of right shoulder pain. The treating orthopedic surgeon at the time, Dr. Walter Pyka, diagnosed impingement syndrome and related it to the use of crutches. Jones claimed that her shoulder complaints ultimately went away prior to the May 2011 incident and that her physical therapist released her to return to work, if she wanted to, on the day of the May 2011 incident. (Jones did not make a loss-of-earnings claim related to the May 2011 or August 2013 incidents.) Four days after the May 2011 incident, Jones presented to her physical therapy appointment related to her prior tibial plateau fracture and reported the May 2011 fall. She again reported the new incident to Pyka eight days later, on May 19, 2011, and to her primary care physician in June and July of 2011. Pyka ultimately referred Jones to a hand specialist for treatment of Jones’ complaints regarding her left thumb. Jones was ultimately diagnosed with a left trigger thumb and prescribed conservative treatment. Eventually, the symptoms resolved. The plaintiff’s treating hand specialist opined that Jones’ trigger thumb was related to the May 2011 incident. In September 2011, Jones began seeing a new treating orthopedic surgeon, Dr. David Atkin, for treatment of her shoulder pain. Jones subsequently received injections of a steroid-based painkiller and underwent physical therapy. When conservative treatment did not resolve her complaints, Jones underwent a successful right rotator cuff repair on Aug. 27, 2013. Atkin opined that one of the findings from the rotator cuff repair suggested that the injury was trauma-related and that he attributed the injury to the May 2011 incident. He noted that although Jones had a pre-existing degenerative condition of the shoulder, there were components that appeared to be trauma-related. Jones claimed that as a result of the February 2012 incident, she sustained sprains of her right knee and ankle. She did not go to a hospital after the incident, but mentioned the fall to her therapist during an ongoing round of physical therapy, indicating that she felt some pain to her knee and ankle. Jones ultimately underwent arthroscopic knee surgery. Atkin testified that the February 2012 incident caused an exacerbation of Jones’ knee complaints, but conceded that he had not seen all of the medical records nor had he reviewed Jones’ two depositions. He testified that his opinion, in large part, relied upon Jones’ history. Defense counsel disputed the cause of Jones’ shoulder condition. Counsel noted that Jones made no complaints about her thumb or shoulder during her physical therapy appointment four days after the May 2011 incident, nor did Jones complain about her thumb or shoulder to her initial treating orthopedic surgeon, Pyka, on May 19, 2011. Counsel also noted that although Jones mentioned the May 2011 fall to her primary care physician in June 2011 and July 2011, she again made no complaints of shoulder or thumb pain. Thus, defense counsel contended that Jones only began to complain of symptoms consistent with trigger thumb in her left hand in June 2011 and only first complained of shoulder pain to Pyka in July 2011. In addition, defense counsel contended that the August 2013 surgical findings from Jones’ shoulder repair revealed a predominant degenerative condition. The defense’s expert orthopedic surgeon conducted an independent medical examination, and reviewed all medical records, both of Jones’ depositions, all of the radiology results, and the films from Jones’ arthroscopy. He also conducted additional medical research. In the defense expert’s opinion, Jones’ shoulder surgery was reasonable, but was only directly related to her degenerative condition in the shoulder. Based upon the medical literature, he testified that trigger thumb is not commonly caused by trauma and, therefore, opined that Jones trigger thumb condition what not caused by the May 2011 incident. Defense counsel also called Jones’ original treating orthopedic surgeon, Pyka, who testified that Jones did not present to him with any shoulder complaints following the May 2011 incident and that Jones only first complained of shoulder pain in the summer of 2011. Relying upon his records, Pyka indicated that if Jones had presented with shoulder complaints, he would have recorded it in his records and that since his records did not have any record of shoulder complaints, it would be consistent that Jones did not make those complaints. However, he opined that the February 2012 incident exacerbated Jones’ pre-existing tibial plateau injury. Both the defense’s expert orthopedic surgeon and the plaintiff’s second treating orthopedic surgeon, Atkin, agreed that Jones may have suffered a slight sprain to the right knee and ankle following the February 2012 incident.