On Jan. 20, 2011, at approximately 8:30 a.m., plaintiff Marylou Escobar, an unemployed 49 year old, went to take out the garbage from her apartment in Los Angeles when she was struck on her right shoulder by debris from the apartment building’s roof. Escobar claimed to her right shoulder. Escobar sued the owner of the apartment building, Provident Housing LLC; the managing member of the LLC, Saman Mostadin; and the roofer that was working on the building, Adolfo Garcia. Escobar alleged that Garcia was negligent for the debris that fell from the roof, and that Mostadin and Provident Housing were negligent for the dangerous condition. Escobar alleged that Provident Housing hired Garcia, an unlicensed roofer, to make repairs on the apartment building’s roof, making it liable for Garcia’s actions. She also alleged that Garcia threw the roofing debris that struck her on the date of loss. Provident Housing and Mostadin claimed that the tenants of the building were provided notice of the roofing work and that a barricade was set up. Garcia did not appear at trial, and a default judgment was entered against him., On the day after the accident, Escobar went to a chiropractor for treatment of alleged shoulder pain, and continued with treatment for six weeks. She then saw an orthopedist for an MRI and was diagnosed with a rotator cuff tear and a SLAP tear of her right, dominant shoulder. Escobar ultimately underwent arthroscopic surgery on her shoulder on Aug. 23, 2011, and followed up with physical therapy through May 2012. She also followed up with her orthopedic surgeon through March 2013. Escobar claimed that she still experiences pain, discomfort and reduced range of motion in her shoulder, and that she will require further shoulder surgery. Thus, she sought recovery of $114,024.84 in past medical costs, $70,000 in future medical costs, and up to $700,000 for her past and future pain and suffering. Counsel for Provident Housing and Mostadin disputed the alleged causation of Escobar’s , as well as disputed the need for the treatment the plaintiff received.