On October 7, 2021, Keanu Peeves, age 15 at the time, was riding his dirt bike (Suzuki RM100)at the gravel pit (called "the Pits") alone. He recalls that he rode his bike at about 10 kilometres per hour in second gear to the top of a gravel cliff along the flat path that followed the crest. He was sitting on his bike and walking it with his feet. It was his intention to see from the top of the hill whether any of his buddies were in the sand piles below. When Keanu got to the top of the hill, however, there was nothing there, and he could not stop, so went straight down off the cliff about 15 to 20 feet to the ground. The hill had suddenly dropped because the owner of the pit,Matrix Sand and Gravel Ltd. had removed half of the hill earlier that day. It was known to everyone that sometimes the terrain changed at the Pits, with hills disappearing week to week because of gravel operations.Keanu has been riding his dirt bike since he was 9 or 10 years old and at the time of the accident was a member of his school's motor cross team. He often rode at the Pits with lots of other kids, and at least 100 times before, including at the hill and the sand pile where the accident happened.The worker at the Pits, Cypher Mouse, never said anything to him or his friends about riding there.On the rare occasion when the old owner was on site, he would yell at the kids to get off his property in a general way but did not do anything else.Keanu sustained a fractured right arm (dominant) with resulting nerve damage requiring surgery and ongoing therapy, although he has skipped a number of his treatment sessions as he is often tired and the clinic is far from his home. He cannot raise his right arm above mid-chest level and he has difficulty completing school work. He has failing grades at his high school, Wick Academy, although his grades were just above failing before the accident. He has also not ridden his dirt bike since the accident nor competed in any motor-cross events. His school coach, Trinity Switch, had told him he was a real strong competitor who could have gone far in the sport. His friends have told him he was one of the best riders they had ever seen at the Pits.Matrix Sand and Gravel Ltd. is a corporation that has been around since the 1970s, leasing land near the Toronto Matrix Docks from Ontario Hydro. The company dredges the bottom of theMatrix River, taking out large quantities of sand mixed with water. After the sand dries and settles in big high piles, it is transported and then sold to buyers. There were "Private Property - NoEntry" and "No Trespassing" signs around the boundaries of the gravel site that had been there for years. There were also gates blocking the road entrances to the Pit

Keanu has brought a Small Claims Court action in negligence against Matrix Sand and Gravel Ltd.for the injuries he sustained on October 7, 2021.

three material facts/elements of case you need to establish for Keanu Peeves and an exhibit/piece of evidence that could be tendered to support that material fact/element, as well as how that particular piece of evidence could be admitted at trial

MATERIAL FACT/ELEMENT OF CASE	POSSIBLE EXHIBIT/EVIDENCE TO BE TENDERED	HOW/WHO WILL INTRODUCE IT
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