On Oct. 3, 2013, plaintiff Florentino Carrera, 46, a roofer, was working on a residential construction site, in Arcadia, when he tripped and fell off a roof. He fell approximately 12 feet before impacting the ground. Carrera sustained to his neck and back. Carrera sued the framing subcontractor, Mora Construction; the owner of Mora Construction, Juan Mora; the general contractor, Eldorado Construction and Management Inc.; and the owners of Eldorado Construction and the property that was being developed, 216 Palm Investments Inc., 216 Palm Avenue Investments LLC, 216 Palm Development LLC, Annie Chan and Ming Chan. Carrera claimed that he tripped on a nail that was left sticking up on the roof by Mora Construction. According to plaintiff’s counsel, in order to install the plywood on the roof, Mora Construction utilized “cleats,” which is a method where nails are partially driven into the roof in order to hold plywood in place while it is cut. Counsel asserted that Mora Construction had negligently left one of those nails protruding from the roof when it completed its work. Plaintiff’s counsel also asserted that Eldorado Construction was negligent because, as general contractor, it had exercised and maintained control of the safety conditions on the construction site, but that it had, nonetheless, failed to ensure safe working conditions. Eldorado Construction claimed it had no knowledge as to how Carrera’s fall occurred. Its counsel also asserted that, as the general contractor, Eldorado Construction had no liability for Carrera’s under the Privette line of cases. Mora Construction denied leaving any nails protruding from the roof, claiming it never utilized “cleats” when installing plywood on roofs. Its counsel noted that a city inspector had examined the roof after Mora Construction completed its work and had approved it. Counsel also contended that one of Mora Construction’s employees had witnessed Carrera’s fall and that Carrera had not tripped on a nail at all, but, rather, had slipped on roofing paper while walking backward. Thus, Mora Construction’s counsel asserted that the fall was caused purely by Carrera’s own negligence and the negligence of his employer. Counsel further asserted that regardless of what had caused Carrera to fall, Carrera and his employer were primarily responsible for Carrera’s because Carrera had failed to secure himself to the roof with a harness, as was required by Carrera’s employer’s own rules., Carrera suffered catastrophic , including a spinal injury that left him with minimal ability to walk. He subsequently was hospitalized for six months and required surgery on his cervical spine at the C4, C5, C6, C7, C8, T1 and T2 levels. Carrera claimed that despite surgery, he now suffers from myelomalacia — a pathological term referring to the softening of the spinal cord — at C7, C8, T1 and T2. He also claimed that he will require a lifetime of attendant care by a nurse.