A trip and fall incident at a Ventura apartment complex has led to a lawsuit alleging negligence and premises liability. On June 13, 2024, Laurie Haynes filed a complaint in the Superior Court of California, County of Ventura, against Michael H. Byrne, Trustee of the Donald Byrne Trust.
The case revolves around an incident that occurred on July 3, 2022. Haynes was walking along a path by the pool outside the gates of her apartment complex at 10880 Del Norte Street when she tripped over an obstruction and fell. According to the complaint, Haynes suffered serious injuries as a result of this fall. The plaintiff asserts that Michael H. Byrne, as the owner and manager of the property, failed to maintain safe conditions on the premises.
Haynes alleges that Byrne breached his duty of care by not ensuring that the pathway was free from obstructions and other hazards. "Defendants owed Plaintiff a duty of care to keep her safe from harm," states the complaint. The document further accuses Byrne and other unnamed defendants (referred to as DOES 1-50) of being negligent in their maintenance and control of the property. The plaintiff contends that this negligence directly resulted in her injuries, which have caused ongoing physical and mental suffering.
The lawsuit seeks various forms of relief including general damages for pain and suffering, special damages for medical expenses incurred and expected in the future, lost wages, loss of earning capacity, and pre-trial interest. "Plaintiff will incur medical, therapeutic and related expenses in the future," reads one part of the complaint detailing Haynes' anticipated ongoing medical needs.
In addition to these claims under negligence, Haynes also brings forth accusations under premises liability law. She argues that Byrne should have been aware of the unsafe condition due to his role as owner and operator of the property. "Defendant knew or should have known of the obstructed pathway," claims Haynes in her filing. She maintains that it was foreseeable someone would use this path to return to their residence and potentially get injured due to its hazardous state.
The case is being handled by Erik Harper from Morgan & Morgan Los Angeles LLP representing Laurie Haynes. The case ID is 2024CUPP025870.