1. Arnold is a city worker performing work on a sidewalk in Downtown Vancouver. He is digging a hole to reach a utility line. The hole is four feet wide, four feet long, and four feet deep. When he is done digging, he secures the area with two orange cones at the corners facing the sidewalk. The cones are one foot tall. There is three feet of sidewalk left for pedestrians. The next morning, shortly after sunrise, Sylvester walks past the hole on his way to work shortly after sunrise. Just as he passes it on a busy morning, his right leg hits the edge of the hole, which causes him to lose balance and fall into the hole. He breaks his right arm as a result and is taken to the hospital.

Sylvester has sued Arnold's employer, the City of Vancouver, for damages. He wants compensation for both the broken arm and the broken leg.

as I am the plaintiff's lawyer and I am looking for points that I can use in front of judges against the defendant's lawyers.

and I need the following points which I can present

Plaintiff's Lawyers

• The plaintiff is Sylvester Stallone
• He is arguing that the City, through Arnold, was negligent
• Sylvester wants compensation for both the broken arm
• Make the best case possible for Sylvester, applying the relevant law to the facts