On Sept. 9, 2016, plaintiff Guillermo Frayre, 50, an on-site maintenance worker for Park Sycamore L.P.’s 59-unit apartment complex, in the Highland Park area of Los Angeles, was attacked by Jeffrey Gallegos, a homeless man. Prior to the attack, a domestic dispute arose in one of the apartment units involving two tenants and Gallegos, a relative of theirs who had unexpectedly visited. The tenants eventually contacted the police after Gallegos threatened them with a knife. Gallegos fled the unit, but before the police arrived, he ran into Frayre, who also lived at the complex, and attacked him. Another tenant of the complex, who was driving into the secured parking lot on his way home from work, observed Frayre on the ground with alleged to his head and face. The tenant arriving home also contacted law enforcement. However, Gallegos fled the scene by the time the police arrived and could not be located by law enforcement. Frayre sued Gallegos; the owner of the complex, Park Sycamore L.P.; and the believed maintainer of the complex, Barrio Management Inc. Frayre alleged that Gallegos’ actions constituted assault and that Park Sycamore and Barrio Management were negligent in their failure to provide adequate security at the complex. Park Sycamore brought a cross-complaint against Gallegos, but the cross-complaint was dismissed before trial. Gallegos and Barrio Management were also dismissed from the case prior to trial, and the matter continued against Park Sycamore only. Plaintiff’s counsel contended that Park Sycamore was aware that the attacker had visited the property on countless occasions over the years, in violation of residency rules, and that the attacker had previously assaulted someone else near the property, as well as engaged in vandalism of the property. Counsel argued that the knowledge of Gallegos’ prior incidents required Park Sycamore to take action to prevent the assailant from entering the property or to evict the tenant relatives so that there would be no incentive for Gallegos to visit. There was substantial evidence at trial on the issue of notice. Multiple tenant witnesses were called to testify about their knowledge of the assailant’s presence on the property and whether management was aware of his presence or conduct. Defense counsel argued that Park Sycamore was not aware of Gallegos’ alleged misconduct. Counsel also argued that there was reasonable security at the complex, in that the complex was secured by a perimeter gate, as well as a locking pedestrian and vehicle gate. Counsel further argued that the complex had on-site management to address property- or tenant-related issues as they arose., Frayre sustained orbital and mandibular fractures. He also claimed he sustained a moderate/severe brain injury with a hemorrhage. He was subsequently transported by ambulance to a hospital for treatment of his . Frayre ultimately underwent surgery to treat his facial fractures. Frayre claimed that he suffers from ongoing major neurocognitive disorder, memory loss and diminished executive functioning. He also claimed that his psychiatric diagnosis is that of adjustment disorder with features of anxiety and depression. Frayre alleged that as a result, he suffers a total loss of independence and requires around-the-clock attendant care. Frayre was responsible for maintaining, among other things, the operation of the perimeter security fencing and gates. Owing to his , Frayre alleged that he would never be able to return to the workforce. Frayre sought recovery of approximately $400,000 in past paid medical expenses, $450,000 in past and future loss of earnings, and $9 million in future medical costs for his medical care/life care plan. He also sought recovery of damages for his past and future pain and suffering. In total, plaintiff’s counsel asked the jury to award Frayre $40 million. It was undisputed that Frayre sustained orbital and mandibular fractures, which required surgery. Frayre’s psychiatric diagnosis was also undisputed. However, defense counsel argued that Frayre’s brain injury was of the mild form with the bleeding not occurring within the brain. Counsel also argued that while Frayre does meet the criteria for a neurocognitive disorder, it is a mild form with limited impact on memory, executive function and independence. In addition, defense counsel argued that the findings on Frayre’s MRI were largely due to pre-existing medical conditions, such as mini-strokes arising from hypertension.