In 2007, plaintiff Kathleen Kelley, a disabled woman in her 50s, began leasing a residential premises in Brookdale. She claimed that immediately upon taking possession of the property, she noted numerous defects, including water intrusion, mold and mildew growth, and deterioration of the exterior decks and stairways. Kelley claimed that these defects were communicated, verbally and in writing, to both the property manager, Scotts Valley Property Management, and the property owner, Todd Sachi, but that substantive repairs were never made. In May 2011, the property manager’s handyman recommended that the exterior deck be replaced. However, this recommendation went ignored, and in April 2012, Kelley tripped over protruding nails on the deck, causing her to fall down five or six stairs. Kelley eventually vacated the property in September 2012. Kelley sued Scotts Valley Property Management and Sachi, alleging premises liability. Prior to vacating the property, the plaintiff’s expert construction consultant inspected the premises and determined that the unit was “substandard,” pursuant to Chapter 10 of the 1997 Uniform Housing Code. According to plaintiff’s counsel, the property was also tested by M3 Environmental, and while the air sampling was fairly normal, visible mold growth was noted throughout., Kelley claimed she suffered respiratory issues and adult onset asthma as a result of the indoor environmental conditions within the property. She also claimed that she sustained rib and other soft-tissue as a result of her fall. Kelley alleged that her total medical expenses amounted to $2,174, of which Medi-Cal paid approximately $218.