On the morning Oct. 20, 2011, plaintiff Bertha Erroa, 53, an assembly line worker, was shopping at Northgate Market Store #34 in Placentia. As she was walking near refrigerated wet racks located near the checkout counter, Erroa slipped and fell while she was carrying a small bag of vegetables. Erroa claimed she injured her right shoulder and leg. Erroa sued Northgate Market, which was doing business as Northgate Market Store #34 and which was initially erroneously sued as Northgate Gonzalez, LLC. Erroa alleged that the defendants failed to properly maintain the subject location, creating a dangerous condition. With the aid of a Spanish interpreter, Erroa provided deposition testimony about the incident. She claimed she slipped on water that had emanated from the refrigeration racks and that she was wet after hitting the ground. Plaintiff’s counsel contended that, due to the frequency of water spilling on the floor next to the wet racks, Northgate Market should have had a floor mat at the location where Erroa fell. Counsel also deposed 10 Northgate Market employees who stated that video surveillance in the store would have captured the incident, as well as any prior floor inspection that day. According to plaintiff’s counsel, a claims adjuster for the defense initially acknowledged in writing that Northgate Market had video and photographs of the incident, and stated that Northgate Market accepted liability. However, after Erroa’s counsel filed suit, Northgate Market denied liability and disavowed the existence of any record of the fall. Defense counsel denied that any water had accumulated at the alleged site of Erroa’s fall. Counsel cited sweep sheet floor inspection logs from the day of the alleged incident, which did not denote a slippery area., Erroa alleged that she was left on the ground for approximately 20 minutes before being helped up by an employee. She then called her son, who spoke to store management and took her to the emergency room at Coastal Communities Hospital, in Santa Ana, where she was treated and released. Shortly after the accident, Erroa underwent several MRIs and was diagnosed with a rotator cuff tear of her right, dominant shoulder and a contusion of her right leg. On May 1, 2012, she underwent arthroscopic surgery to repair the torn rotator cuff. Erroa then underwent additional arthroscopic surgery on April 22, 2014, for further repair of the rotator cuff and the removal of adhesions. Erroa claimed that due to her shoulder injury, she is unable to lift her arm above her shoulder and she is unable lift objects weighing heavier than 10 or 15 pounds. She alleged that as a result of these restrictions, she is unable to work. The plaintiff’s sports medicine expert provided a written report in which he opined that Erroa’s rotator cuff tear was a result of the alleged fall. He also opined that Erroa’s condition following the second shoulder surgery was likely permanent and that Erroa could no longer perform heavy lifting. Defense counsel disputed the nature and extent of Erroa’s alleged shoulder injury. The defense’s expert orthopedic surgeon examined Erroa and provided a written report stating that he found Erroa’s pain complaints to be anatomically unexplainable. He also stated in the report that he did not understand the basis for the alleged functional problem with Erroa’s shoulder.