Whenever a trial date is set, a party may demand simultaneous exchange of expert witness information (Code of Civil Procedure § 2034.210).
If a party fails to comply with the exchange of expert witness information, and the other side objects, “the trial court shall exclude from evidence the expert opinion” of said witness. (Code of Civil Procedure § 2034.300)
The recent case of Perry v. Bakewell Hawthorne, LLC, (2017) Cal. Lexis 1351, raised a novel issue as it relates to the above sections. Perry was a personal injury matter wherein the plaintiff fell on defendant’s property. Defendant moved for summary judgment, which was set to be heard after the exchange of expert witness information.
In his opposition, plaintiff used the declarations of two experts to demonstrate that the stairs he fell on were in disrepair and did not comply with building code and industry standards. The problem was that neither of these two declarants had been identified in the expert witness information exchange.
The issue became whether the exclusionary rule of CCP § 2034.300 applied only to the use of those experts at trial or whether it also applied at the summary judgment stage.
Ultimately, the Supreme Court of California held looked to the Section governing motions for summary judgment – CCP § 437c. They held, Section 437c(d) requires that affidavits and declarations submitted in summary judgment proceedings “set forth admissible evidence.” They held that when the court determines an expert opinion is inadmissible because disclosure requirements were not met, the opinion must be excluded from consideration at summary judgment if an objection is raised.
In this matter, because the declarations attached to the opposition to motion for summary judgment were by two experts whom would be excluded from testifying at trial, their declarations were similarly inadmissible to refute the defendant’s motion for summary judgment.
Published By: Jean-Simon Serrano
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If you've been bitten or attacked by a pit bull in San Bernardino County, you need a local personal injury attorney who has successfully resolved similar dog bite attack incidents. The Paris Firm led by Attorney, Eric D. Paris has been fighting for injured clients in the Inland Empire since 1994, and his reputation for achieving outstanding results speaks volumes about his ability to achieve outstanding results for the firm’s clients.
Dog Bite Attorney in the Inland Empire
Dogsbite.org reports that there were 34 dog bite related fatalities that occurred in 2015, of which pit bulls contributed to 82% of those deaths. Over the years, San Bernardino County officials have been cracking down on pit bull owners due to the highly dangerous statistics regarding their temperament. However, the popularity of pit bulls is overwhelming, and many people are drawn to them even though they're often the #1 "blacklisted" breed by insurance companies in addition to:
Recently in Riverside, California a pit bull was killed by a neighbor after it had attacked and killed his Poodle. The defendant and 2 other neighbors were over-powered by the pit bull and could not get it to release the smaller dog from it's jaws once it had locked down - a characteristic personality trait of the breed.
The Paris Firm Fights & Wins Dog Attack Case
Mr. Paris recently settled a lawsuit by obtaining the entire homeowners insurance policy in the amount of $100,000 for a client who was performing her job when she was attacked by a dog. The dog bit her arm so hard that it crushed clear through to the bone. The client's insurance company was delaying as much as possible which is a common tactic used by insurance adjusters. The Paris Firm filed a lawsuit, conducted an extensive investigation into the matter and after destroying the defendant in deposition the very next day the case settled for the entire homeowners insurance policy.
If you or a family member were attacked by a Pit Bull or any other breed of dog, you should discuss your case with a dog bite injury lawyer who has over 20 years of experience and has handled cases similar to yours. Call Eric Paris to schedule a free consultation today @ (909) 469-5127.
At Heiting & Irwin, we advise Californians involved in a car crash caused by another person to take photographs at the scene of the crash so long as they are able to do so without causing another person’s physical safety or their own safety to be jeopardized. Some may wonder, however, just how important these photographs actually are to the resolution of their Riverside car crash. The answer depends on the quality and quantity of the photographs themselves.
Taking Good Photographs After a California Car Crash
Photographs in a car crash case preserve a crucial moment in time for your attorney and any experts who may be needed to evaluate your crash. The old adage is true: While your words and statements can paint a picture of the accident’s aftermath, a picture truly is worth a thousand words (see, for example, this case).
However, the usefulness of the photographs you take will depend on both the quantity and quality. In general, it is always advisable to take photographs of the car crash scene. However, these photographs may not be of much help to your attorney if they are not of sufficient quality. Quality photographs that are most helpful include those that:
You should also take care to ensure these photographs are properly archived so that you always have a copy available to you in the event other copies become lost, damaged, or destroyed.
Do Not Take Photographs if Doing So Jeopardizes Your Safety
While photographs can be extremely helpful in increasing your chances of recovering compensation in your case, you must not jeopardize your own safety or cause further injury to yourself or anyone else just to take photographs. Not only will this exacerbate your losses, but it can negatively impact your ability to recover full compensation.
As soon as possible, contact Heiting & Irwin for further assistance and representation. Heiting & Irwin is a Riverside car crash law firm committed to helping those injured in collisions caused by the negligent actions of others. We use any photographs our clients are able to take along with our knowledge and investigative resources to build a powerful and persuasive case for compensation for our clients. Let us help you or your loved one obtain monetary damages for your injuries by calling (951) 682-6440. Alternatively, you can complete our online form for assistance.
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Nobody ever really wants to hire a lawyer, but the reality is that at some point you'll need to hire one. The problem is that if you've never hired an attorney, and you have no frame of reference, where do you look for one? The answer is almost always going to be to hire locally. We've written before on how to choose the best attorney for your case, but why does it matter if you hire a local San Bernardino or Riverside lawyer versus an attorney from Los Angeles or Orange County?
Here are the top 5 reasons to hire a local lawyer
There's a recent trend that's been taking place in the last few years. Law firms from LA and Orange County have been setting up "Satellite" offices in the Inland Empire so they can have a local telephone number and office address to give the impression that they're a local firm and appear in the local business section of Google, but there's usually no one there to staff it. Often times their "local" office is little more than a desk, printer and a telephone. So when you need to see your lawyer, they would have to drive in from Downtown Los Angeles or Irvine to meet you. How often do you really think that happens? Local lawyers are typically more accessible because you can drop something off at their office and leave it with their staff, stop by if you have a question or concern, or make an appointment that isn't limited to one afternoon on the only day the attorney is in town.
2) Local attorneys usually know the local judges, courtroom cadence and opposing lawyer
When you hire an attorney outside of the Inland Empire, that individual may have never met the judge they'll be appearing before, they may not know their personality, behavior, likes & dislikes or the way they run their courtroom. Local attorneys attend local mixers, conferences and social events and get the opportunity to develop a rapport with judges and other local attorneys. This should not be misconstrued as a judge favoring a local lawyer, but it's easier for an attorney to prepare and position your case if they know the personalities of the judge and the opposing attorney. Hiring an attorney who's never met the judge assigned to your case or the opposing counsel, and who doesn't know the local courtroom flow may be considered to be at a slight disadvantage.
3) Local attorneys invest, spend and hire locally
An article from Entrepreneur says "Local business owners often have incentive to support other local businesses, patronizing local establishments for both business and personal reasons." Local attorneys are your neighbors and they tend to hire local support staff, pay local taxes, shop at local stores, eat at local restaurants and hire local service providers. When you hire a lawyer from Orange County or Los Angeles, the dollars you spend supports their local community.
4) Many local attorneys are just as qualified for "big cases"
Among some people, there's a perception that you'll get a better result for your case if you hire a "Los Angeles" attorney. While it's true that Los Angeles has some of the best legal talent in the country, chances are good that your case can be equally represented by a well qualified local attorney. Furthermore, there's a chance that the hourly or fixed rate for a local attorney will be far less than a lawyer paying premium rent & overhead for a Los Angeles or Newport Beach office.
5) Reduced Out-of-Pocket Costs
When you hire an attorney the travel costs affiliated with your case are incurred and charged to you. That can include:
If you need to hire a lawyer, the best way to validate that your actually hiring locally is by verifying with the California State Bar of the address on file for an attorney. InlandEmpireLawyers.com has already done this for you by allowing only verified local attorneys to be listed within our directory. This way, you can be assured that the attorney you contact is genuinely local to San Bernardino & Riverside County.
Even though it has been six years since the Affordable Care Act became law, politicians continue to debate ways to curb what appear to be ever-increasing costs of healthcare services. The battle against rising healthcare costs began long before the Affordable Care Act’s passage, however, and saw a number of states enacting medical malpractice caps that limit the amount of damages a medical malpractice claimant can recover in a lawsuit. Lawmakers believed such caps could be useful in lowering healthcare costs in that the amount of compensation a doctor or medical provider would be liable for would be restricted, thereby making the costs of medical malpractice liability insurance more affordable (and, hence, reducing the amount of the medical malpractice insurance premium that the doctor needed to “pass on” to his or her patients in the form of higher costs for services.
California's Medical Malpractice Cap Limits
California is one of many states that have passed a “cap” on the amount of noneconomic damages that a medical malpractice plaintiff can receive. The Medical Injury Compensation Reform Act (MICRA) was passed in 1975 and limits medical malpractice plaintiffs to a maximum of $250,000 in noneconomic damages.
In any civil lawsuit, a plaintiff may allege that he or she has suffered “economic” harm as well as “noneconomic” harm. Economic harm consists of financial expenses and losses that a person experiences as the result of another person’s negligence: in the case of a medical malpractice case, this can include additional medical expenses, prescription drug costs, and time missed from work. “Noneconomic” harm refers to those losses that are not financial in nature – things like a person’s mental pain and suffering or the loss of enjoyment of life the person experiences as the result of his or her injury.
While MICRA restricts the amount of monetary damages that a plaintiff may receive for his or her noneconomic damages, no such cap is placed on the amount of economic damages that the plaintiff can receive. In other words, the plaintiff’s economic losses (at least the ones he or she can satisfactorily prove to the court) can be fully compensated, regardless of the actual amount of damages incurred. Conversely, no matter how severe the plaintiff’s pain and suffering or how limited his or her life now is because of the medical mistake, it is unlikely that he or she will recover more than $250,000 for those losses.
Helping Injured Patients in California for 40 Years
When you have been injured by a doctor’s or surgeon’s medical mistake, you may find yourself and your family facing hundreds of thousands of dollars in economic and noneconomic losses. Heiting & Irwin is your Riverside medical malpractice law firm. We want to help you recover from your tragic injury and obtain the compensation you need to pull your life back together. Contact our firm at (951) 682-6400 or by using our firm’s online contact form.
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While most people are preparing for Christmas and New Year’s Eve during the month of December, roughly 1 in 5 spouses are planning to file for divorce in January according to a survey done by the law firm of Irwin & Mitchell in 2015.
Why? No one wants to spoil the holidays with a divorce filing and most people want to stick it out for Christmas morning and New Year’s with the kids. For some, divorce can turn into a New Year’s resolution, a way to take back control of your life and direction. Let’s face it, if you’re in a terrible marriage and you’ve been considering divorce for a while January is widely considered as a “fresh start” month for most things.
James McLaren, partner at McLaren & Lee, is quoted as saying “We see a significant increase in people seeking out divorce advice and, ultimately, filing. The number of filings is one-third more than normal. That begins in January and probably goes into early March” in an article published by Market Watch.
If you’re considering filing for divorce in San Bernardino or Riverside County and want to explore your options, you should consult with a local lawyer ass soon as possible. Your attorney will be able to counsel you on how to best prepare for the separation and provide advice on how to prepare for changes in financial matters, housing, child care, spousal support and numerous items that you haven’t yet considered. Even if you and your spouse plan on an amicable & cooperative divorce, an experienced lawyer can help provide insight into the process and help you navigate the filings, procedure and timelines. Here are a few important reasons to hire a local attorney.
Click HERE to review some of the local divorce attorneys serving courts in San Bernardino and Riverside Counties. InlandEmpireLawyers.com allows you to quickly click to an attorney’s profiles & reviews from popular websites like Yelp, AVVO and Martindale-Hubbell as well as their California Bar listing. This allows you to expedite your research, validate that the attorney is in good standing with the State of California and allows you to avoid having to spend hours exploring the experience and reputation for each lawyer.
Once you contact a lawyer, tell them you found them on InlandEmpireLawyers.com!
While people experience many types of serious injuries in motor vehicle collisions, falls, and other accidents, the brain is one of the most vulnerable of vital organs in the human body. A traumatic brain injury (TBI) can have debilitating consequences that last a lifetime, including diminished cognitive functioning, impaired mobility, and inability to communicate, just to name a few examples. Traumatic brain injuries often have a profound effect on both a victim and his or her family. Our experienced Rancho Cucamonga injury lawyers have answered common questions we frequently receive from people who have suffered head injuries because of the misconduct of an individual, business, or public entity.
What should I do if I suffer a traumatic brain injury in an auto accident caused by another party?
The most important step to take in the wake of a serious accident during which you incur a brain injury is to seek immediate medical care. Some head injuries do not exhibit significant symptoms until some time has elapsed after an accident. This delay in symptoms frequently is related to bleeding and swelling inside the skull, which imposes increased pressure on the brain. When injury victims take a “wait and see” attitude after experiencing an injury in a car accident, they risk a less favorable prognosis because unrelieved pressure on the brain might cause severe brain damage and even death. Prompt treatment also enables medical providers to conduct a thorough diagnostic examination. A magnetic resonance imaging (MRI), computerized tomography (CT), or electroencephalography (EEG) scan often provides vital evidence regarding the nature and severity of an accident victim’s injuries.
Brain injury victims also should seek prompt legal advice if they are injured in a collision caused by the conduct of another. The potential magnitude of damages in a lawsuit involving a serious TBI means that insurance companies will devote extensive resources to shift blame to the injury victim or to otherwise avoid liability. Medical evidence regarding the nature of the brain injury and the way the crash caused the injury also will involve complex medical information that must be explained to a jury with experts. Our Inland Empire personal injury lawyers work with well-regarded experts to build a compelling case for our clients.
How much is a traumatic brain injury claim worth?
While the precise value of a brain injury will depend on a range of factors, the damages in a case involving a traumatic brain injury typically exceeds $100,000, and awards in the millions are fairly common. The amount recovered in a judgment or settlement does not equal the actual compensation an injury victim receives. Our law firm handles auto accident claims on a contingency fee basis, which means that any attorney fees are a percentage of the client’s recovery. The litigation costs associated with pursuing a brain injury case also typically will be deducted from the recovery, including expert fees, trial exhibits, day-in-the-life videos, deposition costs (e.g. court reporter fees), and other costs associated with pursuing the lawsuit. The expenses associated with litigating a traumatic brain injury case can easily amount to tens of thousands of dollars, but our Southern California law firm has the financial resources to advance these costs of litigation. Our law firm executes a written fee agreement with every client, so they know what to expect regarding their net recovery after paying attorney fees and litigation expenses.
Can I pursue a personal injury lawsuit if I suffered a brain injury several years ago?
While the best practice is to seek legal advice as soon as practical after suffering a brain injury, the statute of limitations can bar the claim if a lawsuit is not filed before the deadline expires. A law firm will need time to investigate your injury claim and prepare a complaint to initiate the lawsuit, so time is of the essence in retaining legal representation. Further, shorter deadlines might apply, such as lawsuits against public entities for unsafe roads.
If you have suffered serious injury or lost a loved one in an auto collision, tractor-trailer accident, or motorcycle crash caused by a distracted or unreasonably careless driver in Southern California, our experienced Rancho Cucamonga personal injury lawyers at Schwartzberg & Luther, APC are dedicated to aggressively pursuing a maximum recovery for our clients. Contact Schwartzberg & Luther, APC at (909) 457-4270 to schedule your free consultation!
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What you Should Know About Mass Tort Litigation
Those afflicted with insomnia have undoubtedly seen them: Late night television ads from so-and-so law firm advising viewers to call “immediately” if they have taken a certain prescription drug or used a particular medical device. The advertisement will usually list serious-sounding side effects and entice you to call the particular law firm by promising significant cash compensation for physical injuries and mental pain. Are these promises too good to be true?
In many cases these commercials are paid for by law firms looking to file a significant number of cases (sometimes thousands) against one or a few defendants. This is known as mass tort litigation. This is not the same as a class action suit (in which many similarly-situated plaintiffs join in one singular suit against a defendant or defendants).
While these advertisements may make it seem as if your prescription medication or medical device can be your ticket to a huge compensation award, there are some principles to keep in mind before agreeing to participate in such litigation:
You should not stop taking medication without speaking with your doctor: Some of these advertisements leave you with the impression that your health is in immediate danger if you are taking a specified medication or are using a particular device. However, immediately stopping a medication – even a potentially dangerous one – without first talking to your own doctor can be extremely harmful to your health. If you believe you are suffering negative side effects from a drug or medical device, you should speak with your doctor immediately.
Contact a Product Liability Attorney Right Away
If you or a loved one have been injured by a defective product or dangerous drug, the Riverside product liability law firm of Heiting & Irwin wants to speak with you. We will give your situation and circumstances personalized attention and will fight for a just and equitable resolution in your case. Call us at (951) 682-6400, or contact us through our website’s online contact form.
When a uniformed San Bernardino County Sheriff’s Deputy or a private process server personally serves you with divorce papers, you might experience a flood of emotions that include anxiety about the future. Few events have the impact of a marital dissolution because it impacts so many aspects of your life, including your parenting relationship, monthly income, net worth, and future financial security. Many people do not anticipate they will be involved in a divorce, so they are unsure how to protect their rights and safeguard their relationship with their children. The actions you take in the aftermath of receiving a Summons and Petition for Marital Dissolution in San Bernardino or Riverside County can have a dramatic impact on the outcome of your divorce. In this blog post, our Rancho Cucamonga divorce lawyers offer a list of important steps to take if you are served with divorce papers in the Inland Empire.
Carefully Review the Paperwork
The first paperwork people typically receive in a divorce include a Summons and Petition along with some ancillary documents. The Summons (California divorce form FL-110) will indicate that you have thirty days to respond to the Petition (California divorce form FL-100) if you wish to participate in the divorce process. If your divorce is heard in San Bernardino family court or another courthouse in San Bernardino or Riverside Counties, you might also receive notice of an Order to Show Cause. If you receive this document, you should make sure to calendar the court date and seek immediate legal advice. The hearing will be to consider temporary orders (also called “pendente lite” orders) that could involve child custody or visitation, spousal support, temporary possession of your residence, child support, attorney fee advances, and other important issues.
The Summons also includes Automatic Temporary Restraining Orders (ATROS). ATROS are mutual orders that are summarized on the back of the Summons of a Petition for Dissolution. ATROS are restraining orders that restrict the conduct of both parties. These restraining orders are designed to prevent either party from taking actions that will prejudice the other spouse by diverting, encumbering, transferring, concealing or disposing of assets, including insurance policies. ATROS also prohibit a parent from removing minor children from the state without the prior written consent of the other parent. Violation of these orders can carry harsh penalties, so you should seek legal advice before engaging in significant financial transactions or relocating your children.
Speak to an Experienced Inland Empire Divorce Lawyer
Many people will make the mistake of attempting to prepare their own Response and to proceed without an attorney (referred to as proceeding “pro per”). The way you respond to a Petition and Order to Show Cause can have a profound impact on your parenting relationship, finances, property ownership, obligations to pay debts, and living arrangements. Further, parties that attempt to handle their own divorce while their spouse is represented by legal counsel tend to experience undesirable outcomes because the attorney can exploit the unrepresented party’s lack of knowledge regarding court procedures, evidentiary rules, and substantive law.
Even if you believe you and your spouse have resolved most of your issues, an attorney can ensure that your proposed settlement is enforceable, identify any potential pitfalls, and draft the necessary paperwork to obtain your judgment. There are many mistakes that can cause a proposed settlement to go off the rails when parties proceed without attorneys. Sometimes parties will attempt to fashion a settlement based on terms that are not enforceable under California law, such as parents attempting to waive child support. In other situations, the parties might not consider unforeseen issues that make their agreement unfair or unworkable. Further, artful drafting of an MSA or parenting plan by an experienced Southern California divorce lawyer can prevent future disputes and repeated trips back to court for enforcement or modification proceedings.
File a Response or Default
If you fail to respond, the divorce can proceed without your involvement, which means your spouse will likely obtain a judgment consistent with his or her requests (referred to as a “default divorce” or “uncontested divorce”). If you have already resolved all of the issues in your divorce with your spouse, you might elect to allow the divorce to proceed via default. However, you should not allow your divorce to proceed on a default basis without speaking to an experienced Southern California divorce lawyer. Default only constitutes a viable option if no assets or debts have been acquired during the marriage. If the parties have children, a default divorce will not be appropriate because you will want to be involved in decisions regarding parenting time, decisions about major parenting issues, and child support. Divorces that proceed via default also tend to be brief (e.g. a few months duration) so that spousal support is not at issue.
In most cases, you will want to respond within the required time by filing a Response (Form FL-120). The response permits you to indicate your preferences in broad terms regarding child custody and visitation, property division, spousal support, child support, and related issues. The Response also allows you to indicate that you want separate property confirmed to you or that you have a different perspective regarding the facts or outcome of your divorce.
Post-Response Proceedings: Once you have filed a Response, your marital dissolution will proceed to a conclusion along one of two paths. If you and your spouse resolve all of your issues, you can prepare a Marital Settlement Agreement (MSA) which will memorialize the terms of your settlement. The MSA will become a key part of the judgment in your marital dissolution. If you do not reach an agreement, the judge will make orders on unresolved issues. Some temporary orders will be entered during Show Cause hearings while others might be resolved at a Court Conference. The judge can resolve any matters during a trial that are not settled by the parties.
Special Note for Divorcing Parents: When parents divorce, the process is far more complicated. Both parents must participate in mediation in an attempt to reach an agreement on legal custody and parenting time. If the parents cannot agree, the judge might order an attorney to represent the children (referred to as “minor's counsel”). Minor’s counsel will make recommendations to the court regarding the appropriate custody and visitation orders. The judge also might decide that a Child Custody Evaluation must be performed. During this process, the evaluator will meet with both parents and the children and conduct an investigation to determine the best interest of the children. The report and recommendations will carry significant weight with the judge, so parents should make sure they speak to an experienced Inland Empire divorce lawyer about preparing for a custody evaluation. The divorce process becomes especially perilous for parents involved in a child custody dispute without legal representation.
If you have been served with divorce papers in San Bernardino or Riverside Counties, our experienced Inland Empire family lawyers at Schwartzberg & Luther, APC are committed to providing effective legal representation to pursue the best outcome for you and your children. Contact Schwartzberg & Luther, APC at (909) 457-4270 to schedule your free consultation!
Schwartzberg | Luther are attorneys in Rancho Cucamonga focusing on family & divorce law, criminal defense, personal injury and insurance bad faith. Working with clients throughout Southern California and all courts in San Bernardino and Riverside Counties.
Thermostats are starting to rise throughout the Inland Empire as summer quickly approaches. Many homeowners are getting their swimming pools ready to fend off triple digit temperatures. While pools and spas can provide recreation and exercise, they also can constitute a significant safety hazard. In the United States, the CDC reports that more than 3,300 fatal drownings occur in swimming pools in a typical year. One in four of these deaths involves a child under the age of 14. Drowning is the second leading cause of death for children 5 and under, trailing only auto accidents. There are almost twice as many children who suffer serious injury in near-drowning incidents each year, which often results in permanent disability and brain damage.
Courts often consider swimming pools attractive nuisances to children because pools tend to attract children who are too immature to appreciate the potential risk of harm. Homeowners or those who operate commercial pools have an affirmative duty to implement safeguards designed to prevent children from drowning or suffering an injury in other pool-related accidents. When the failure of pool owners to take adequate safety precautions causes drowning or other injuries, our experienced Inland Empire personal injury attorneys represent swimming pool accident victims.
In investigating a swimming pool accident, there are several questions that arise:
Pool areas are usually equated with fun whether located at a resort, friend's houses, or health clubs. Unfortunately, pools can be extremely dangerous hazards when certain conditions exist.
Diving injuries can happen when depth markings are faded, not visible, or non-existent.
The lack of fencing around a pool can spell danger for children who are wandering around unsupervised. When there is no safety equipment at the pool, this can result in drownings when a swimmer gets in trouble. If a public pool is open, adequately trained and attentive lifeguards should be present. Entrapment accidents can occur without proper maintenance of pool drains, filters, and pumps. Underwater obstructions like a shelf or rock grotto structure can cause catastrophic brain injuries.
While property owners often can be liable for injuries caused by an unsafe swimming pool, some other parties also might share financial responsibility. Defective pool pumps and heaters or poorly constructed life-saving equipment can also cause serious injuries. When pool equipment causes an injury or fatality, the company that designed, manufactured, or sold the defective product might be liable for injuries caused by the defective equipment or part. The company that built the pool also might be liable for defective work that causes injuries or a drowning.
If you or someone you love suffers an injury in a swimming pool accident at a residence, community, or resort swimming pool, our experienced Inland Empire accident attorneys carefully investigate the circumstances of such incidents and diligently pursue the best result for our client. Schwartzberg & Luther, APC offers tenacious advocacy designed to obtain the best possible results for our clients.
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