Woman Trips and Falls Outside Sacramento Department Store, Part 2 of 5

The following blog entry is written from a defendant’s position as trial approaches. Reviewing this kind of briefing should help potential plaintiffs and clients better understand how parties in personal injury cases present such issues to the court.

(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this trip and fall/personal injury case and its proceedings.)


On March 14, 2007, Judy Brown and her husband Kenneth drove to the Universal Mall (“Universal”) in Sacramento, California. Mrs. Brown had been to Universal several times in the past. After two hours of shopping, she exited the mall through the same route that she entered. Mrs. Brown’s husband had exited about ten minutes earlier and she proceeded outside to meet him in the parking lot.

As she proceeded to the car, she was not paying attention to anything in particular and was looking straight ahead. The next thing Mrs. Brown realized was that she had hit the ground and jumped right back onto her feet. She did not feel her foot catch the pavement, nor does she have any evidence as to what might have caused her to fall.

At the time of her accident, Mrs. Brown was wearing flat-soled walking shoes and carrying two bags. Mrs. Brown testified that on the day in question, the area where she traversed was clear of leaves and debris. The weather on the day of the accident was beautiful and sunny. Further, she stated that she had no problems seeing and there were no shadows on the concrete. Plaintiff later measured a raised area between two concrete slabs where she alleges she tripped and found it to be one-half inch or less in height. (See Part 3 of 5.)

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

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