Brown

I. Background.

Defendant Beach House Design and Development (Beach House) was the general contractor responsible for remodeling a residence in Hermosa Beach, California (the property). Beach House subcontracted with O’Rourke Construction, Inc. (O’Rourke) to do finish carpentry, and with A&D Plastering Co. (A&D) to erect scaffolding and to patch plaster. Plaintiff, a carpenter, was employed by O’Rourke. On June 16, 2017, O’Rourke’s carpenters, including plaintiff, were on the property to mill, prime, and install window casings. After lunch, while working by himself, plaintiff fell from the north side of the building onto a concrete walkway, suffering

2 severe injuries. It appears that no one saw plaintiff fall, and plaintiff has no recollection of the incident. After plaintiff’s fall, Jeffrey Strnad, Beach House’s principal, and Alex Daniels, A&D’s principal, inspected the scaffolding above the area where plaintiff fell. They found that some of the scaffolding was not properly secured to the building, and planks, crossbars, ties, and guardrails had been cut or were missing. Both men said the scaffolding was not safe to use in that condition.

II. The present action; Beach…