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Philadelphia County

The plaintiff was making a delivery to the defendant, Moore College of Art & Design, in Philadelphia when she claimed that she slipped and fell on an unsafe ramp to the defendant’s loading dock. The plaintiff alleged that the ramp was too steep and lacked an adequate handrail. The defendant denied that the loading ramp was dangerous and argued that the accident stemmed from the plaintiff’s own negligence. The defense also disputed the injuries which the plaintiff claimed to have sustained as a result of the incident.

The plaintiff was a 46-year-old female delivery person at the time of the accident on a rainy morning, June 27, ________. She testified that, at 10:15 a.m. that morning she was making a delivery at the defendant’s Wilson College Hall. The plaintiff testified that she slipped and fell while pulling a hand truck filled with cargo and the hand truck pin struck her in the left knee.

The plaintiff alleged that the defendant’s ramp violated the applicable building code because it was three times as steep as the code allowed. The plaintiff also contended that the handrail on the ramp was inadequate due to its wide circumference, and that the defendant failed to install a non-slip surface on the ramp. The plaintiff’s building expert testified that the ramp should have been extended out 37 feet more in order to conform to building code regulations.

The plaintiff was transported to the emergency room by ambulance after the accident. The plaintiff’s doctors testified that the plaintiff sustained post-traumatic cervical and lumbar myofascitis, radiculopathy at the C-6 level, disc protrusions at C4-C5 and C3-C4, aggravation of preexisting stenosis at C4-C5, occipital neuralgias, a torn meniscus in her left knee, chondromalacia of the left patella and a traumatic patellofemoral syndrome in her left knee as a result of the fall. A year and a- half after the accident, the plaintiff underwent arthroscopic surgery on her left knee. Her doctors testified that a cervical surgery is also indicated for the future. The plaintiff sought past medical expenses of $________ and future medical expenses, including the cost of cervical surgery, of $________.

The plaintiff alleged that her injuries are permanent and prevented her from continuing her employment as a delivery person. The plaintiff claimed between $________ and $________ in past and future loss of wages. The plaintiff was divorced with two children.

The defendant argued that the ramp was reasonably safe. The defense maintained that it was raining and that the plaintiff was carrying too much on the hand truck and was hurrying up the ramp. The defense contended that the plaintiff should have used techniques taught by her employer which directed her to use alternate entrances when there was a safety concern regarding the primary loading area.

The defendant also argued that the plaintiff’s symptoms were the result of a prior neck injury which occurred on September 20, ________, while the plaintiff was at work. On that occasion, the plaintiff was on a freight elevator that dropped abruptly and then stopped sharply. The plaintiff complained of neck pain and she was in treatment for four months until January 20, ________ and thereafter returned to work.

The defendant’s medical expert testified that the plaintiff’s MRIs from October ________ compared with her MRIs after the subject accident (taken in November ________) showed no change and thus no new injury. In addition, the defense argued that the surgical notes from the plaintiff’s knee surgery indicated that the condition was not trauma-related. The defense asserted that the plaintiff’s medical condition was not changed by the subject fall and that she could return to her prior employment as a delivery person with no loss of earnings.

The jury found the defendant ________% negligent and awarded the plaintiff $________ in damages. The award included $________ in past medical expenses, $________ for future medical expenses, $________ million for past and future lost wages and $________ in pain and suffering. Plaintiff’s counsel filed a motion to recover $________ in delay damages. The case is currently on appeal.

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