On Dec. 7, 2011, plaintiff Lori Ryan, an unemployed woman in her 50s, was helping her friend, Max Knight, paint the interior of a rental property in Novato to help prepare it for rental or sale. However, as she climbed onto a ladder, she slipped on paint that she had tracked onto the ladder, causing her to slip and fall from the first step. Ryan claimed to her neck, lower back, and hips. Ryan sued Knight and the owner of the rental property, the Beverly A. Knight and Richard T. Knight Revocable Trust. Ryan claimed that Knight spilled paint onto the tarp in the area where she was planning to help him paint. She alleged that as a result, she unknowingly tracked the paint onto a ladder, causing her to slip and fall while she was climbing on it. Ryan contended that since Knight spilled the paint, he should have warned her about the dangerous condition. Knight denied spilling the paint or failing to warn Ryan. Defense counsel disputed the accident even occurred, noting that no one witnessed Ryan’s alleged fall. However, counsel contended that even if the fall did occur, Ryan set up her own work area, so Ryan was responsible for the paint in her area. Thus, counsel asserted that Ryan was responsible for her accident., Ryan claimed that she sustained soft-tissue to her neck, lower back, and hips. She subsequently underwent nerve block procedures and a rhizotomy for pain relief. She also underwent a hip arthroscopy on one side. Ryan claimed that she now has chronic pain syndrome and that she will require multiple rhizotomies and a hip replacement for the same hip. She also claimed that she is unable to participate in activities and that she is now disabled. Specifically, Ryan testified she could no longer drive or lift anything heavier than five pounds. She also testified that walking long distances hurt her and that she could no longer enjoy horseback riding and riding motorcycles. Thus, Ryan sought recovery for her past and future pain and suffering, as well as a recovery of damages for her past and future pain and suffering. Defense counsel contended that Ryan had chronic back pain for 10 years before the subject accident and that Ryan did not complain of hip pain for four months after the incident. Thus, counsel asserted that none of Ryan’s alleged were caused by the fall. In addition, defense counsel asserted that Ryan did not fall off the ladder, since nobody witnessed the incident and since emergency room records indicated that Ryan developed back pain because she was moving furniture. The defense’s medical experts opined that Ryan may have had minimal aggravation of her pre-existing complaints, but that Ryan most likely had a pre-existing back condition. They also opined that Ryan’s hip injury was not related to the subject accident.