On Dec.12, 2011, plaintiff Raquel Lopez, a self-employed woman in her 40s, was at a Walmart store in Chula Vista when she tripped and fell over a mat within the store. She subsequently injured her right, dominant shoulder in the fall. Lopez sued Wal Mart Stores Inc. Lopez claimed that the mat was negligently maintained, causing it to become a dangerous condition. She also claimed that Walmart was generally negligent because it had notice of the mat’s lack of maintenance. The plaintiff’s safety expert opined that the mat was negligently maintained, as it would not have moved if it had been cleaned properly. Defense counsel contended that the mat was properly maintained, that all procedures and policies were followed, and that all industry standards were followed, as well., Lopez was taken to a hospital on the day of the accident and then underwent an MRI about two or three weeks later. She claimed she suffered soft-tissue to her back and the MRI revealed a torn rotator cuff to her right dominant shoulder. Lopez underwent chiropractic treatment, physical therapy and consultations with an orthopedist. However, she did not complete any therapy treatment because she allegedly required rotator cuff surgery, but she has not undergone any surgery on her shoulder yet. Lopez claimed that although her back have resolved, she lost the ability to work and function normally due to the constant pain in her shoulder and an inability to raise her right arm above shoulder level. She also claimed her shoulder condition caused her to be unable to continue teaching Zumba classes, resume her active lifestyle, or carry her grandchildren in her arms and play with them. She alleged that as a result, she suffers from depression and weight gain. Thus, the plaintiff’s medical expert opined that Lopez requires rotator cuff surgery to repair the injury to the right shoulder.