On the afternoon of March 5, 2011, plaintiff Virginia San Felipe, 47, an accountant, was doing laundry at the Peninsula Place Homeowners Association in San Bruno, where she lived. San Felipe claimed that while she was walking down an exterior wooden staircase, located in the common area, she slipped and fell toward the end of the staircase, landing right-knee-first on the concrete ground below. San Felipe sued Peninsula Place Homeowners Association. San Felipe alleged that the defendant failed to properly repair and maintain the staircase, creating a dangerous condition, and that the defendant had notice of said condition. San Felipe contended that the step she slipped on was worn with a knothole, which caused her to slip and fall as she descended the exterior staircase. She claimed the staircase was not repaired or renovated since the mid-1960s, even though the Homeowners Association set aside reserve funds to replace its staircases every 10 years and chose not to do so. Defense counsel argued that San Felipe gave inconsistent reports to her doctor on when and where she fell, in that San Felipe said she might have fallen inside her apartment. Counsel also argued that subject staircase had ordinary wear and tear that did not put the Homeowner’s Association on notice to replace the staircase. In addition, Peninsula Place claimed San Felipe regularly used the staircase and was aware of its condition., On the day after the incident, San Felipe went to her primary care physician and underwent an X-ray, which revealed a right patella fracture. She then followed up with an orthopedic surgeon, who confirmed a comminuted fracture of the right knee. On March 10, 2011, San Felipe underwent open reduction and internal fixation, with the insertion of pins and wire. Her leg was then placed in a cast and a hinged knee brace, and she received roughly one month of physical therapy. San Felipe returned to work in May 2011, but claimed continuing pain, weakness and discomfort in her right knee. She also claimed her knee gave way with continued pressure. As a result, San Felipe underwent an MRI, which revealed lateral and medial tears of the right knee’s meniscus. It was further determined that her hardware was causing her pain. On April 13, 2012, San Felipe underwent a second arthroscopic surgery. However, it was decided not to remove the hardware when it was discovered it was embedded in the bone growth. San Felipe claimed she still experiences pain and discomfort in her right knee. She claimed that as a result, hardware removal surgery and a potential total right knee replacement have been recommended. San Felipe alleged that her knee condition has made kneeling very difficult and that she can no longer play for her company softball team. She also alleged that she now self-treats with physical therapy. Thus, San Felipe sought recovery of $10,400 in past medical costs (post-Howell), $19,800 in past lost earnings, $12,000 to $23,000 in future medical costs, and an unspecified amount of damages for her pain and suffering. Defense counsel contended that San Felipe’s lost earnings claim was excessive and that her claim for future medical costs was exaggerated, based on what San Felipe paid for her past medical costs.