The Plaintiff was a commercial painter operating a scissors lift at the Defendant landowner’s premises. A furnace pit was covered with plywood which the Plaintiff alleged to be concealed. When operating the scissors lift over the furnace pit, the plywood broke, causing the scissors lift to tip over. The Plaintiff sustained a severe fracture of the left femur for which he underwent four surgeries, three of which resulted in a non-union. This 56 year-old Plaintiff was permanently disabled and will always walk with a cane. The Plaintiff entered into evidence economic specials of $358,000.