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Centurion was subjected to heavy rainfall resulting in numerous potholes. Municipal workers of the City of Tshwane were instructed to repair all potholes on walkways

Centurion was subjected to heavy rainfall resulting in numerous potholes. Municipal workers of the City of Tshwane were instructed to repair all potholes on walkways in the area to prevent further damage which could be detrimental to pedestrians. The Municipal workers were busy repairing one of the walkways that were damaged by the heavy storms. During their lunchbreak, the workers walked to a nearby cafe to buy food. They left the big cavity in the walkway unattended and did not cordon it off or put up any signs warning the pedestrians of the hazard. Dr Mary Motsepe, who works at a nearby hospital embarked on her customary lunch hour jog along the walkway. Mary is nearsighted but leaves her spectacles in her office because she perspires profusely during her jog. While sprinting the final stretch of her jog, Mary notices the cavity in the walkway too late. She slips and falls into the cavity. She breaks her arm, fractures two ribs and sustains a severe concussion. Mary was admitted to hospital where she was treated for a period of 2 months due to the severity of her injuries. Mary is traumatized by the incident and is now reluctant to jog outdoors. Draft the particulars of claim that Dr Motsepe must lodge in the High Court, where she claims both general and special damages. In your answer, provide very clear heads of damage and describe them fully, in terms of the applicable Uniform Rules of Court that govern pleadings of this nature

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