On Nov. 10, 2017, plaintiff Barbara Williams, 51, a paralegal, exited the vehicle her husband parked near the south curb, facing east, near 212 San Vicente Blvd., Santa Monica. As she was walking to the back of the vehicle, she tripped and fell. Williams fell between the curb and the sidewalk, landing on her face. She claimed she sustained to her head, face, back, right knee and left hand. Williams sued the owner and maintainer of the area, the city of Santa Monica. Williams claimed that the subject area constituted a dangerous condition of public property and that the city failed to repair and/or maintain the area. Williams claimed that she tripped on an exposed, 2- to 3-inch tree root that was located between the curb and sidewalk and that the city’s failure to repair the dangerous condition caused her fall. Counsel also noted that after Williams’ reported the incident to the police, the area was taped off with yellow tape, and the city’s employees came to the area and sawed off the exposed roots. Defense counsel asserted that Williams was aware of the parkway tree roots, as they were open and obvious., Paramedics transported Williams to the emergency room at Providence Saint John’s Health Center, in Santa Monica, where Williams was diagnosed with blunt force trauma to her head, resulting in a headache. She was also diagnosed with contusions to her face, right knee and the thumb on her left hand; as well as multiple abrasions, including abrasions to her face. Williams was evaluated and ultimately released from the hospital. Williams claimed the subject accident caused an injury to her lumbar spine at the L5 level, which caused radicular pain into a leg. She underwent physical therapy and ultimately received a sacroiliac (SI) joint injection. Williams also claimed her head injury caused memory issues, recurring headaches, mood changes and vision changes, as well as aggravated a prior traumatic brain injury. Williams previously sustained a traumatic brain injury in a motor vehicle accident in 1986, when she was 20 years old. She claimed that she recovered quite well from the incident and that she was eventually able to successfully complete college and continue working. However, Williams claimed that the trip-and-fall incident on Nov. 10, 2017, aggravated her prior TBI, resulting in new symptoms, such as memory problems, headaches and vision loss. She alleged that by Nov. 30, 2017, her headaches and other symptoms had become so frequent and painful that she presented herself to a board-certified neurologist at a Cedars Sinai medical facility. In addition, based on a referral from her primary care physician, Williams presented to an optometrist at a Cedars Sinai medical facility on Dec. 13, 2017. During that doctor’s visit, Williams complained of blurred vision in the left eye, which she claimed she had since the subject fall. Williams had to take time off from work because of her , but she was eventually able to go back to work and did not seek a loss of income. However, she claimed that she will continue to need physical therapy to treat her lower back pain. In addition, she is left with a facial scar with pigment loss that extends from her left nostril to her left cheek, which she claims is permanent. Williams only sought recovery of damages for her past and future pain and suffering. Defense counsel questioned whether Williams’ memory impairment, cognition and mood changes were related to the subject accident or were the result of Williams’ prior TBI.