Plaintiff Jose Flores, 45, placed a ladder on a scaffold to paint a storefront, in Pasadena, when he fell about 10 feet and landed face first. He subsequently claimed to his head and both wrists. Flores sued the operator of the store, M & N Rug Enterprises LLC. Flores contended that he was a statutory employee under the Labor Code and that the store was negligent. Defense counsel denied that Flores was hired by M & N Rug Enterprises. Counsel also argued that Flores was liable for the accident by improperly placing the ladder on the scaffold., Flores sustained fractures to both wrists. He also claimed he also sustained a mild traumatic brain injury. Defense counsel disputed that Flores sustained any injury in the fall, noting that there were no findings on the MRI.