Higgins

facts were true.” In its second summary judgment motion, Environmental Design submitted a new declaration from the maintenance supervisor who oversaw Environmental Design’s work at the Restoration Hardware store. In granting summary judgment, the trial court found Environmental Design met its initial burden on summary judgment and Higgins did not create a triable issue of fact because the evidence Higgins presented—that an Environmental Design employee used the same ladder on Restoration Hardware’s rooftop garden two months earlier—did

2 not support a reasonable inference that an Environmental Design employee negligently placed the ladder in the storage room. Higgins contends the trial court erred in overruling her objections to the declaration of the maintenance supervisor and she presented circumstantial evidence an Environmental Design employee placed the ladder in the storage room. This time, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

A. The Complaint On May 12, 2020 Higgins filed this action against “Doe Gardeners” and individual unnamed gardener defendants, asserting a single cause of action for negligence. Higgins alleged that on June 17, 2018, while she was…