On June 30, 2009, at approximately 1:20 p.m., plaintiff Jose Lara, 61, a UPS truck driver, went to Arco Towers in Los Angeles to deliver and pick up packages. He subsequently backed his truck up to the loading dock, opened up the rear roll-up door, and placed his delivery cart on the dock with three loads of packages. In order to make the transition to the dock from the floor of the UPS truck, located two feet below dock level, Lara grabbed onto a handrail in the UPS truck with his right hand and attempted to step up and across the 14-inch space between the truck and dock. However, his left foot went through the space between the metal step of the UPS truck and the face of the dock, striking the concrete floor four feet below. As a result, Lara claimed to his knees, and left foot and leg. There were no eyewitnesses to the subject accident. There was a video camera aimed directly at the area of the accident, which security personnel testified was working, but that the images were taped over every two weeks. Lara sued the property manager, Jamison Services Inc., and the owner of the building, 1055 West Seventh LLC. Lara alleged that the defendants were negligent for failing to properly maintain the loading dock, thereby creating a dangerous condition. Lara claimed that as he stepped up and across the space between the truck and dock, he put his left foot into contact with a 3-inch-wide metal edge strip on the dock, but that he felt his left foot slip off the metal edge strip and go down through the space between the UPS truck and the dock, striking the concrete floor. Lara’s counsel contended that the building ownership and management knew that delivery truck drivers regularly stepped up from their trucks onto the dock and that there was a smooth metal edge strip that did not have any slip-resistant properties, but that they failed to do anything about it. The plaintiffs’ civil engineering expert produced 12 different examples of slip-resistant materials that could have been used on the subject dock edge, and testified that any one of these materials would have provided slip-resistance and prevented the accident. The defense’s biomechanical expert concluded that Lara’s left foot slid down the face of the dock, and the defense’s engineering expert opined that the metal edge strip was not slippery and had a coefficient of friction of .65 and higher. The defense’s property manager expert opined that the defendants had no notice of any prior accidents or complaints, and that a metal edge strip was within the standard of practice. Defense counsel contended Lara mis-stepped and did not contact the top of the metal edge strip, but rather missed it entirely. Thus, counsel argued that Lara was the cause of the accident., Lara sustained a severe fracture of the Lisfranc joint complex to his left foot, fractures of his left fibula and torn menisci in his knees. He was subsequently taken from the scene of the accident by ambulance and brought to an emergency room. He ultimately underwent two surgeries on his left foot, open reduction and internal fixation with the insertion of a plate and screws on his fibula, and arthroscopic surgery and Orthovisc injections to both knees. Lara claimed his foot injury did not heal properly, requiring him to undergo 30 hyperbaric oxygen chamber treatments. He also claimed he has been on pain medication since the accident and will require surgery on his knees. In addition, Lara claimed he became depressed due to his inability to return to work as a UPS truck driver or enjoy his active life as he did before the accident. Thus, Lara, sought recovery of $250,000 in future medical costs, $200,000 in past lost earnings, $600,000 in future lost earnings, and an unspecified amount of damages for his past and future pain and suffering. He also claimed he had $187,000 in past medical costs, which was paid by UPS. Lara’s wife, Antoinette Lara, presented a derivative claim, seeking recovery of damages for her loss of consortium. In addition, Mr. Lara’s worker’s compensation carrier, Liberty Insurance Corp., entered the case as a plaintiff-in-intervention in order to recover a lien of $325,000. Defense counsel argued that any need for future knee surgery, as alleged by Mr. Lara, was the direct result of Grade 3 and 4 chondromalacia of both knees, and not a result of the subject accident.