Attorney Frank Lombardo settled this action prior to trial for $1,200,000.00 (out of $1,500,000 in available insurance coverage). The plaintiff, a 35-year-old laborer, fell through an opening in the attic floor while spraying insulation of a one-family residential home undergoing renovation. The plaintiff sustained a closed reduction non-united hypertrophic avulsion fracture, a tear of the posterior horn of the medial meniscus of the right shoulder, and an anterior cruciate tear. The plaintiff’s injuries required arthroscopic surgery and resulted in post-concussion syndrome, anxiety, and depression. Summary judgment on liability was denied due to questions of fact as to whether the general contractor or the homeowner was acting as a general contractor. The general contractor contended that they were merely assisting the homeowner, one of their employees, with obtaining materials. The homeowner contended that he was in the employ of the general contractor and did not direct or control the work. At trial, one of the defendants would have been relieved of liability, which would have reduced the insurance coverage by $500,000 to $1,000,000. Frank was able to settle this matter prior to trial while managing to procure almost all of the available insurance.