Attorney Erin K. Hurley settled for $1.5 million, plus a full waiver of the workers’ compensation lien, during discovery for a construction worker. Our client was carrying 2-in x 4-in wood from the foundation excavation up a muddy earth ramp when he slipped on the mud and fell. He injured his left shoulder, left knee, and lower back, which required surgery. Defendants claimed they were never informed of this accident and didn’t believe it happened. Further, they argued that the case was dismissible under existing case law because this was an open excavation site.