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Image 1: Employee enters elevator vestibule. Carpet tiles, with “seams” created using duct tape, have been laid down for flooring protection during construction project.
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Jay Kerr Law: Premises Liability

Jan 27, 2017

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Jay Kerr
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Page 1: Jay Kerr Law: Premises Liability

Image 1: Employee enters elevator vestibule. Carpet tiles, with “seams” created using duct

tape, have been laid down for flooring protection during construction project.

Page 2: Jay Kerr Law: Premises Liability

Image 2: Duct taping over tile “seam” (circled) is partially detached, creating a raised edge

tripping hazard which existed prior to Employee’s encounter.

Page 3: Jay Kerr Law: Premises Liability

Image 3: Enhanced view of detached duct taping and raised edge at seam.

Page 4: Jay Kerr Law: Premises Liability

Image 4: Additional enhanced view of detached duct tape creating raised edge and tripping hazard.

Page 5: Jay Kerr Law: Premises Liability

Image 5: Depicts the left, side-edge of Employee’s left foot adjacent to the raised edge of detached duct tape, immediately before her left foot is caught on the raised edge as she takes a

step.

Page 6: Jay Kerr Law: Premises Liability

Image 6: As she takes a step, the left-edge of her shoe is caught by the raised-edge of detached duct tape. As evident on the video, her left shoe “rolls” slightly due to her body momentum over the brief capture of her foot by the detached edge of duct tape, causing her to lose her

balance and fall.

Page 7: Jay Kerr Law: Premises Liability

Image 7: After her left shoe edge contacts the section of raised duct tape, it causes the tape seam to detach further and furl more narrowly.

Page 8: Jay Kerr Law: Premises Liability

Image 8: Unable to regain her balance, Employee falls to her left side, injuring her left arm.

Page 9: Jay Kerr Law: Premises Liability

Image 9: This image depicts the further detachment of the duct tape from the seam, in contrast to its condition prior to contact by the left-edge of Employee’s shoe (see image 3).