On Nov. 16, 2017, plaintiff Svetlana Hovhannisyan, 70, fell while a patient at Laguna Honda Hospital and Rehabilitation Center, in San Francisco. Hovhannisyan was previously admitted to Laguna Honda to recover from a craniotomy, in which a portion of her skull was removed. As a result, she was scheduled to undergo a cranioplasty in February 2018 to replace the missing portion of her skull. She was also classified as a high fall-risk patient during the first few weeks of her stay at Laguna Honda. On Nov. 16, 2017, Hoyhannisyan awoke at 3 a.m. and needed to use the bathroom. She eventually got out of bed on her own, but was later found on the bathroom floor, having fallen. Hovhannisyan claimed that her left side was weaker after the fall, but that she refused to participate in physical therapy for fear of another fall. She also refused to take Lovenox, which was prescribed to her after the craniotomy to prevent a deep vein thrombosis. Hovhannisyan subsequently complained of pain in her right leg and knee. She was eventually taken to the emergency room at Zuckerberg San Francisco General Hospital and Trauma Center, in San Francisco, because of severe pain and swelling. Doctors at the hospital determined that Hovhannisyan had developed a blood clot in her right leg. On Jan. 18, 2018, Hovhannisyan was transferred to the University of California, San Francisco Medical Center, where she underwent a surgery to have an inferior vena cava filter placed in her chest. The IVC filter was placed to prevent a clot during the scheduled February 2018 cranioplasty, which could not be delayed because of concerns about her health deteriorating. Hovhannisyan sued Laguna Honda Hospital and Rehabilitation Center; the owner and operator of the rehabilitation center, the City and County of San Francisco; and the entity believed to have employed staff at the rehabilitation center, The Regents of the University of California. Hovhannisyan alleged that the defendants failed to properly monitor her and that this failure constituted medical malpractice, elder abuse and neglect. She also alleged that Laguna Honda was inadequately staffed and that the staff on hand had not been properly trained or supervised. Hovhannisyan’s daughter, Arpine Zurfluh, acting as guardian and ad litem, was initially named as the plaintiff in the lawsuit. However, Zurfluh was later dismissed from the case, with Hovhannisyan, herself, named as the plaintiff. In addition, it was determined that the City and County of San Francisco was the owner and operator of Laguna Honda Hospital and Rehabilitation Center, and therefore liable for its actions, and that The Regents of the University of California did not employ any of the physicians or nurses involved in Hovhannisyan’s care at Laguna Honda Hospital and Rehabilitation Center. Thus, the parties stipulated that Laguna Honda Hospital and Rehabilitation Center and The Regents of the University of California should be dismissed from the case, and Hovhannisyan filed a second amended complaint, in which the City and County of San Francisco was the only named defendant. Hovhannisyan claimed that the City and County of San Francisco failed to ensure that proper safety protocols were in place and followed at Laguna Honda and that as a result, she fell. Specifically, she claimed that at the time of her fall, she was attempting to go to the bathroom, but that she eventually had to get out of bed on her own because no one responded to the nurse call button. Hovhannisyan also claimed that Laguna Honda’s employees failed to ensure that she was taking the Lovenox medication and that employees’ failure to do so resulted in the development of a blood clot. She further claimed that the invasive procedure of placing an IVC filter into her chest would not have been necessary if Laguna Honda’s employees had made sure she was taking her prescribed medication. Thus, Hovhannisyan claimed that she suffered a decline in her health due to Laguna Honda’s negligence, for which the City and County of San Francisco was liable. Defense counsel denied each and every allegation against the City and County of San Francisco. Specifically, counsel asserted that Hovhannisyan was the sole cause of her , as it was Hovhannisyan’s choice to go to the bathroom on her own, which resulted in her fall, and was Hovhannisyan’s choice to stop participating physical therapy and taking Lovenox, which resulted in her weakness and blood clot. Counsel further asserted that even if the City and County of San Francisco was found to be partially at fault, Hovhannisyan should also be held partially liable for the accident., Hovhannisyan claimed she experienced weakness on her left side after her fall. She also developed a blood clot in her right leg. She was later transferred to the University of California, San Francisco Medical Center, to undergo the surgical placement of an inferior vena cava (IVC) filter in her chest. Upon her admission to the hospital, it was determined that Hovhannisyan was confused, could barely walk and needed assistance to go to the bathroom. Hovhannisyan alleged that when she was admitted to Laguna Honda, she would have been able to return to working after her recovery. However, she claimed that she now lives with her adult daughter due to her delayed recovery after the cranioplasty. She also claimed that her daughter now has to provide her with 24/7 care. Hovhannisyan further claimed that she will not be able to recover and will continue to require assistance and she can no longer work or live independently, as she did before her admittance to Laguna Honda. Hovhannisyan sought recovery for her past and future medical costs, and past and future pain and suffering. Defense counsel asserted that Hovhannisyan’s condition was caused by her own refusal to participate in physical therapy and take her prescribed medication (Lovenox). Counsel further asserted that even if Hovhannisyan was injured in the fall, she failed to mitigate her condition by undergoing physical therapy and taking her Lovenox.