Ten-year-old Robby Johnson lives at 1234 Your Street in [Your City, Your State], with his parents Jane and Joe Johnson.In April of 2020, Jane and Joe hired Sam Jones, sole owner of Green Grass of Home Landscaping, to redo their large backyard.Part of the plan included the installation of a new privacy fence abutting the neighboring property.As the crew was digging post holes for the fence, Joe grew concerned about the property lines, so the fence was shortened by 2 feet just to be safe.A new hole was dug to accommodate the post for the shorter length of the last fence panel.

On May 9, 2020, Jane, very pleased with her new yard, wrote Sam Jones, a check for the balance owed and asked him about removal of the remaining debris and several hedges, which had been dug up to allow for installation of the fence.Sam reminded her that "full clean-up was part of the job cost" and stated that he would "send out a couple of guys with a truck in the next day or so. They'll fill in that last post hole we didn't end up using, too, and put some grass seed down."Since the job itself had gone smoothly and Brian had thus far behaved very professionally, Jane was fine with that response at the time.A week later, however, the debris and bushes remained, so Jane called and left a voicemail inquiry.That call, as well as many others placed over the next several weeks, went unanswered.Finally, on June 15th, Sam Jones phoned the Johnson and apologized profusely for the delay.Apparently, he sold a truck leaving his cell in the glove box, and the purchaser had only returned it the previous day.Sam said he was shocked and furious upon learning that his clean-up crew had not completed the job and assured them he would be out to take care of it on the morning of the 16th.No one showed up to fulfill that promise.

On Saturday, June 27th, 2020, as Robby was running in the yard with the family dog, his leg landed in the post hole which, by that time, was nearly entirely covered by grass that had grown over the hole itself.In the fall, Robby sustained injuries to his face, including a laceration requiring stitches, a permanent scar, a chipped tooth, and other cuts, scrapes, and bruises. His $300 Nintendo Switch and his $150 eyeglasses were broken in the fall.On Sunday, July 5th, a neighbor saw a group of men driving a Green Grass of Home Landscaping remove the hedges and debris left on the property while the Johnson's attended church and a Sunday brunch.

Immediately following the fall, Robby went to the emergency room of Hope Hospital.He has subsequently seen a dentist, plastic surgeon, eye doctor, and his pediatrician. Since the accident, Jane and Joe Johnson have incurred medical bills and expenses as a result of Robby's treatment. They hired a lawyer to sue the responsible parties.

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