(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this personal injury case and its proceedings.)
It is worth noting that situations similar to those described in this slip and fall case could just as easily occur at any of the supermarkets in the area, such as Safeway, Raley’s, Bel Air, SaveMart, Walmart, or Whole Foods. For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.
Deposition of Store Manager Tom Miller (Designated PMK)
In response to plaintiffs’ CCP 2025 notice for corporate representative most knowledgeable about store procedures, XYZ Market produced its store manager, Tom Miller. In his deposition quoted below, Mr. Miller confirmed that every employee has an obligation to maintain a lookout for slip hazards, and clean them up when they see them:
Q. All right. Let’s talk a little bit about XYZ Market’s floor inspection or sweep policy. Is it XYZ Market’s position that safety is every employee’s responsibility?
Q. You have a slogan, Don’t pass it by, pick it up, correct?
Q. If an employee sees something on the floor such as liquid or debris, they’re supposed to pick it up immediately; is that right?
A. Attend to it as soon as they can, yes.
Q. Is liquid on a store floor a safety hazard?
Q. Are foreign substances on the floor a safety hazard?
Q. Does every employee have an obligation to check the floor in areas where they’re working?
Mr. Miller testified further:
Q: And the question I wanted to ask you about this is that it appears that this confirms — down in the third bullet point, it says, Maintaining hazard-free floor conditions requires everyone’s attention. Regardless of your assigned duties, you are responsible to maintain a clean, dry, hazard-free floor. So my question to you would be that that confirms every employee out on the floor shares that responsibility, right?
A. Sure. Absolutely. (Miller deposition.) (See Part 6 of 12.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.