As costumer leaves stage, she falls into an unguarded hole. $1.7M. Los Angeles County.

Summary

Production employee falls into an unguarded opening in the floor, says studio is negligent.

The Case

  • Case Name: Jill Stager v. Paramount Pictures Corporation
  • Court and Case Number: Los Angeles Superior Court / 22STCV07338
  • Date of Verdict or Judgment: Monday, August 19, 2024
  • Date Action was Filed: Tuesday, March 01, 2022
  • Type of Case: Highlighted Verdicts, Premises Liability
  • Judge or Arbitrator(s): Hon. Karen Moskowitz
  • Plaintiffs:
    Jill Stager, 57, costumer
  • Defendants:
    Paramount Pictures Corporation
  • Type of Result: Jury Verdict

The Result

  • Gross Verdict or Award: $1,735,074.21
  • Net Verdict or Award: $1,719,092.17
  • Award as to each Defendant:

    Full verdict against Paramount Pictures Corporation.

  • Contributory/Comparative Negligence: None.
  • Economic Damages:

    $1,119,092.17 ($15,982.04 not disputed added post-verdict)

  • Non-Economic Damages:

    $600,000

  • Trial or Arbitration Time: 11 days
  • Jury Deliberation Time: 3 1/2 hours
  • Jury Polls: 10-2 on liability and damages.
  • Post Trial Motions & Post-Verdict Settlements: None yet.

The Attorneys

  • Attorney for the Plaintiff:

    Krissman & Silver LLP by Jarod Krissman and Ian Deady, Long Beach.

  • Attorney for the Defendant:

    Wilson Elser Moskowitz Edelman & Dicker LLP by Larry Lum and Ashan Peiris, New York City and Los Angeles.

The Experts

  • Plaintiff’s Medical Expert(s):

    Jonathan Falakassa, M.D., orthopedic surgery.

  • Defendant's Medical Expert(s):

    Douglas Gula, DO, orthopedic surgery.

  • Plaintiff's Technical Expert(s):

    Tim Lanning, economics.

    Joanne Latham, vocational rehabilitation and life-care planning.

  • Defendant's Technical Expert(s):

    Steve Molina, vocational rehabilitation.

Facts and Background

  • Facts and Background:

    Plaintiff was a costumer for the TV production "This is Us." The production was filming on Stage 3 at Paramount Studios. While the production was filming a night scene with the house lights off, plaintiff sought to exit the stage. She walked through a doorway that led to an unguarded and uncovered floor opening and fell into it.

  • Plaintiff's Contentions:

    That defendant had control over the accident location and was negligent in the use and maintenance of its stage and connecting utility closet.

  • Defendant's Contentions:

    That Paramount had no control over the accident location and that plaintiff caused her own injuries.

Injuries and Other Damages

  • Physical Injuries claimed by Plaintiff:

    Fractured sacrum and three broken ribs. While plaintiff did not need surgery, she was left with chronic lower-back pain.

Special Damages

  • Special Damages Claimed - Past Medical: $15,982.04
  • Special Damages Claimed - Future Medical: $ 110,335.00
  • Special Damages Claimed - Past Lost Earnings: $ 233,498.00
  • Special Damages Claimed - Future Lost Earnings: $ 775,259.17

Demands and Offers

  • Plaintiff §998 Demand: On September 5, 2023: $1,350,000
  • Defendant §998 Offer: On September 6, 2023: $500,000

Additional Notes

Per defense counsel:

There is an appeal issue based on judicial error in directing the jury that they could find Paramount liable even without a specific finding of control over the accident location, which was a specific question raised by the jury based on a discrepancy between the jury instruction and the first question on the verdict sheet.