Plaintiff’s heirs alleges that the Estate, Owner of the Subject Property, Failed to Exercise Reasonable Care Causing the Wrongful Death of the Plaintiff
Defendants THE ESTATE, owned, maintained, controlled, managed, insured, and rented the premises known as 2320 West 24th Street, Los Angeles, California 90018.
On or about February 15, 2011 at approximately 8:30 a.m., plaintiff , a resident of the premises known as 2320 West 24th Street, Los Angeles, California 90018 tripped and fell on the subject premises and suffered a broken neck as a result thereof.
At the aforementioned time and place, defendants, and each of them, negligently maintained, managed, controlled the premises located at 2320 West 24th Street, Los Angeles, California 90018, in that the rear area of the subject premises contained various cluttered, miscellaneous, unmarked scattered items that the defendants knew, or in the exercise of reasonable care should have known, constituted a dangerous condition and unreasonable risk of harm. Defendants negligently failed to take steps to either make the condition safe or warn of the dangerous condition, all which caused plaintiff to trip and fall causing her to suffer injuries and death.
As a proximate result of the negligence of the defendants, and each of them, plaintiff, was hurt and injured in her health, strength, and activity, sustaining injury to her nervous system and person, incurring general damages according to proof.
As a further proximate result of the negligence of the defendants, and each of them, plaintiff, incurred medical and related expenses according to proof.
As a further proximate result of the negligence of defendants, and each of them, plaintiff’s earning capacity has been impaired, in an amount according to proof.
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