On April 14, 2011, plaintiff Shelley Keith, an unemployed 62 year old, went to the third-story rooftop patio/common area of her apartment building at 4417 Hazeltine Avenue in Sherman Oaks. As she stepped through the doorway from the building to the outside rooftop, she tripped and fell onto the concrete floor, landing on the right side of her face, her head, neck and chest. Keith sued the operator of the building, Karraa Family Trust; the building’s management company, Karraa RSM; and the building owners, Elias Karraa and Florence Karraa. Keith alleged the defendants were negligent in their failure to repair the rooftop’s dangerous condition. She claimed that as she stepped through the doorway of the building, she tripped on the landing. Thus, Keith contended that the subject landing was in violation of § 91.3304(h) of the 1985 City of Los Angeles Building Code. Defense counsel argued that Keith was at least comparatively at fault for the accident. Counsel contended that if Keith tripped on the threshold step at the rooftop doorway, as she alleged, then Keith caused her own fall by either failing to safely traverse a condition already well known to her (since she had been to the roof in years past), and/or by failing to safely observe where and how she was walking., Keith sustained multiple facial fractures, including maxillary, zygomatic, and nasal fractures. She also sustained lacerations, bruises, and swelling to her face, neck and chest. She was subsequently taken from the scene of the accident by ambulance and brought to an emergency room, where she was diagnosed with a concussion (with suspected intercranial bleeding), right-sided peripheral nerve damage, top right lip numbness, and hypersensitive teeth. Keith also claimed the accident caused a flare-up of her trigeminal neuralgia, a pre-existing condition, on the right side of her face/head. As a result, she underwent a rhinoplasty and reconstructive surgery to correct the facial fractures on the right side of her face. Specifically, on May 25, 2011, Keith underwent open reduction and internal fixation using titanium plates and multiple screws, as well as decompression of the right infraorbital nerve, open reduction and internal fixation of a displaced fracture of the right orbital floor, open reduction and internal fixation of her nasal fractures, and an excision of nasal and right cheek scars with advancement flap reconstruction. Keith claimed she has a permanent facial deformity, as well as nerve damage, and will likely continue experiencing unimproved severe facial pain for the rest of her life. She also claimed she will most likely require future Restylane injections to make her face more symmetrical, approximately every four months, for a total cost of $24,000, and that she might also undergo a nerve stimulation implant at an estimated cost of $68,500. Keith further claimed that she must see her dentist every three months, at a cost of approximately $120 per visit, for the remainder of her expected lifetime, amounting to roughly $7,680. In addition, she claimed she requires additional medication and is entitled to explore cold laser treatments in the amount of $1,600. Thus, Keith sough recovery of $100,000 for her total estimated future care and treatment, approximately $23,468.89 in past medical costs (reduced per Howell), and an unspecified amount of damages for her past and future pain and suffering. Defense counsel agreed that Keith’s pre-existing, atypical facial pain was related to her alleged and damages.