On Feb. 10, 2015, plaintiff Gilda De Paz, 66, a house cleaner, was cleaning a house located on Preuss Road, in Los Angeles, when she fell on a stairway. De Paz sustained to her right arm and left wrist. De Paz sued the owner of the house, VPMG 1772 Preuss, LLC, and the person leasing the house, Vivian Aryeh. Plaintiff’s counsel contended that the stairway was too steep and lacked an appropriate handrail. Counsel also contended that the defendants knew about the stairway’s dangerous condition, but failed to warn about the condition or perform any repairs to make it safe. Just prior to trial, De Paz settled with Aryeh, who agreed to tender her insurance policy limits. VPMG admitted liability and causation, and the matter proceeded to trial on damages only., De Paz sustained fractures of her right, dominant humerus and elbow, and a fracture of her left, non-dominant wrist. She was immediately taken to Cedars-Sinai Medical Center, in Los Angeles, where she underwent open reduction and internal fixation on her shoulder and wrist. De Paz spent three days in the hospital before undergoing several months of therapy. De Paz claimed that despite treatment, she is left with limited range of motion in her right shoulder, weaker grip strength due to her left wrist injury, and occasional pain in her right elbow. De Paz waived her economic damages at trial, and sought recovery of non-economic damages for her past and future pain and suffering. Defense counsel noted that the plaintiff’s treating surgeon and the defense’s expert surgeon both agreed that De Paz eventually attained full functional range of motion in her right shoulder and only has a slight loss of grip strength in her left wrist. Thus, defense counsel disputed the amount of non-economic damages alleged by De Paz.