On July 25, 2015, plaintiff Theresa De Los Santos was walking near the pool area of her apartment building on West Olympic Boulevard, in Los Angeles, when she stepped on a metal drain pipe cover, which was in the middle of the walkway and near flush to the ground, as the cover was intended to be walked on. However, De Los Santos claimed that the drain cover slipped forward more than a half an inch when she stepped down and that as a result, her toe caught the raised edge of the drain, causing her to trip and fall forward. She claimed to her face, right arm and right shoulder. De Los Santos sued the maintainers of the property, D.S.L. Construction Corp., Scott Properties Inc. and Scott Properties. De Los Santos alleged that the defendants failed to properly maintain the drain cover, creating a dangerous condition. The Scott Properties entities were ultimately dismissed from the case. Plaintiff’s counsel contended that D.S.L. Construction failed to choose a proper drain pipe cover and used a cover with flimsy metal prongs, which are prone to wear out, to hold the cover in place, instead of using a full-circle attachment that would have prevented movement. Counsel also contended that D.S.L. Construction failed to replace the loose cover, or do anything to fixate it in place, which caused it to slip forward. Plaintiff’s counsel further contended that the raised lip around the cover presented a tripping hazard and that the combination of the loose cover and the raised lip created a trap to unsuspecting pedestrians. D.S.L. Construction’s counsel contended that De Los Santos was inattentive while walking and was a fall risk, as she had a personal history of multiple falls and a long history of opioid dependence and abuse., Unable to catch herself, De Los Santos struck the ground and sustained a comminuted fracture of her right, dominant arm’s humerus and a full-thickness tear of her right, dominant shoulder’s rotator cuff. She also suffered significant facial lacerations, requiring 21 stitches to repair. De Los Santos initially required an open reduction with internal fixation surgery on her right shoulder. She then underwent a second surgery to undergo a reverse shoulder replacement. Plaintiff’s counsel contended that all of De Los Santos’ subsequent medical care, including both of De Los Santos’ surgeries and the significant long term complications of the reverse shoulder replacement, were related to the sustained in the fall. Counsel also contended that, as a result of complications, De Los Santos was permanently disabled and unable to participate in basic life activities, such as driving a car, due to the significant dysfunction in her dominant arm. De Los Santos sought recovery for her past and future medical costs, and past and future pain and suffering. Defense counsel asserted that although De Los Santos’ initial surgery was related to the fall, De Los Santos’ second surgery was completely unrelated to the subject incident and, instead, was the result of a subsequent rotator cuff tear of unknown cause. Counsel also asserted that De Los Santos had numerous prior to her right arm and other areas of her body that caused disability and depression and that most of De Los Santos’ long term issues were related to those prior and conditions, and not from the sustained in the subject fall.