notes={"A1":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"dorisgoodenough@gmail.com","note_num":"A1","c_note":"","noteMode":"DocNote","note":"Registrar Of Companies : 4th Defendant is in voluntary liquidation","comment":"2nd Defendant was negligent in not monitoring whether ot not 4th Defendant carried public liability insurance.","is_private":"0","docnum":"78","tbi":"","page":"1","recordref":"","atlines":"","is_chron":"0","RAG":"amber","textract":"COMPANYSUMMARYOOOOCOSC CSCSCSC*S\nName DRACO DEMOLITION\n Status VOLUNTARY LIQUIDATION\nRegistration number 2007-18077 823\nRegistration date 2007\/09\/11","descrip":"2Nd Def Disc Item 17. Windeed Company Search","dated":"2019-04-24","hidden":"0","xnote_num":"","xnotexcase_id":"","xdocnum":"","xdocxcase_id":""},"A11":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A11","c_note":"","noteMode":"DocNote","note":"Document Evidence : SGB quoted 2nd Def to erect scaffolding","comment":"But 4th Defendant erected it","is_private":"0","docnum":"72","tbi":"","page":"1","recordref":"CL21267","atlines":null,"is_chron":"0","RAG":"green","textract":"","descrip":"2Nd Def Disc Item 11. Sgb Contract Quotation","dated":"2015-06-06","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A13":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"dorisgoodenough@gmail.com","note_num":"A13","c_note":"","noteMode":"DocNote","note":"Document Evidence: Third Defendant refuses to disclose the identity of the owner of the shopping centre.","comment":"This suggests that First Defendant realised that it was exposed to potential liability and told Third Defendant not to let on who owns the shopping centre","is_private":"0","docnum":"32","tbi":"","page":"20","recordref":"CL19-20","atlines":"","is_chron":"0","RAG":"red","textract":"We are aware of the incident that\ntook place. The matter was dealt with through our insurance company and we have since\nconsidered this matter closed.\n4. The purpose of your request for information is unclear from your abovementioned letter. Kindly\nelaborate on your reasons for the request.","descrip":"Plaintiff Discovery Items 1 - 20. Mostly Emails, Medical Invoices, Reports","dated":"2020-11-12","hidden":"0","xnote_num":"","xnotexcase_id":"","xdocnum":"","xdocxcase_id":""},"A16":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A16","c_note":"","noteMode":"DocNote","note":"Document Evidence: Second Defendant calls for medical records","comment":"","is_private":"0","docnum":"32","tbi":"","page":"22","recordref":"CL19-22","atlines":null,"is_chron":"1","RAG":"","textract":"Second Defendant s Attorneys insofar\nas she is able to do so, within 10 (TEN) days from service hereof, any medical reports, i\nhospital records, X-ray plates, photographs, or other documentary information of a like\n- nature relevant to the assessment of such claims. .","descrip":"Plaintiff Discovery Items 1 - 20. Mostly Emails, Medical Invoices, Reports","dated":"2020-11-12","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A18":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A18","c_note":"","noteMode":"DocNote","note":"Document Evidence: First and Third Defendants call for discovery from Plaintiff","comment":"","is_private":"0","docnum":"33","tbi":"","page":"10","recordref":"","atlines":null,"is_chron":"1","RAG":"","textract":" first and third defendant\n_ require the plaintiff to:\n14 Make discovery on oath ","descrip":"Plaintiff Discovery Items 21 - 32 Mostly Emails","dated":"2019-03-20","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A2":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"dorisgoodenough@gmail.com","note_num":"A2","c_note":"","noteMode":"DocNote","note":"Medical Expert: fractured radius","comment":"There was broken bone but elbow fracture not noticed","is_private":"0","docnum":"48","tbi":"","page":"1","recordref":"","atlines":"","is_chron":"0","RAG":"","textract":"DIRECTORS ASSOCIATES CONSULTANT\nDr. SM Mph |B \/ .\nDr AD.Sacks(MBBCHEF-Red(O)SAL 5 Br MVahOmar (Mscn@(re.Pe fas(0)SA] MB BON,PF Rad () S.A]\nOr M. Stanojevic [M D (Balg.) F.C. Rad (0) S.A\nDr R. Such (M.B.6.CH.,F.C. Rad (D) S.A.)\nDr M","descrip":"1St&3Rd Def Discovery Item 8 Radiology Report 20 Nov 2015","dated":"2015-11-30","hidden":"0","xnote_num":"","xnotexcase_id":"","xdocnum":"","xdocxcase_id":""},"A20":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"dorisgoodenough@gmail.com","note_num":"A20","c_note":"","noteMode":"DocNote","note":" Letter from 2nd Def Aty To Pf Aty : Second Defendant delivers its plea","comment":"","is_private":"0","docnum":"33","tbi":"","page":"14","recordref":"0019-41","atlines":"","is_chron":"1","RAG":"","textract":"DATE: 25 March 2019\ndi YOUR 10137281\/T HARDIE\/K WAGNER\nREF\nDear Sir,\nIN RE: .\nThe above matter refers.\nKindly find attached the Second Defendant's Plea herein.","descrip":"Plaintiff Discovery Items 21 - 32 Mostly Emails","dated":"2019-03-15","hidden":"0","xnote_num":"","xnotexcase_id":"","xdocnum":"","xdocxcase_id":""},"A22":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A22","c_note":"","noteMode":"DocNote","note":"Document Evidence: Plaintiff attorney asks Sheriff to serve joiner application in Draco","comment":"By this time Draco was unbeknown to Plaintiff already in voluntary liquidation","is_private":"0","docnum":"33","tbi":"","page":"17","recordref":"","atlines":null,"is_chron":"1","RAG":"","textract":"10 October 2019\nYOUR\nREF:\nDear Sir\/Madam\nRE :\nThe above matter refers.\nAnnexed hereto please find the Notice of Set Down in duplicate for urgent service on:-\nDRACO DEMOLITION CC","descrip":"Plaintiff Discovery Items 21 - 32 Mostly Emails","dated":"2019-10-10","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A24":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A24","c_note":"","noteMode":"DocNote","note":"Court Document : Plaintiff serves Notice of Amendment consequential upon joinder","comment":"This was delayed because Fourth Defendant was evading service of joinder application","is_private":"0","docnum":"34","tbi":"","page":"3","recordref":"0019-51","atlines":null,"is_chron":"1","RAG":"","textract":"Kindly take notice that Plaintiff, consequential upon the joinder of Fourth\nDefendant as a Defendant in the action under the above case number, intends\nto amend her Particulars of Claim","descrip":"Plaintiff Discovery Items 32 - 35 Mostly Emails","dated":"2019-12-12","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A26":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A26","c_note":"","noteMode":"DocNote","note":"Letter Pf Aty To 2nd Def Aty : Plaintiff requests details to help trace Fourth Defendant","comment":"The fact that Fourth Defendant is so hard to trace gives some indication that it is a fly-by-night business and that Second Defendant was reckless in appointing it to erect the scaffolding. #Note: I must check whether the written agreement stipulates that it is indeed Fourth Defendant who was instructed to erect the scaffold","is_private":"0","docnum":"34","tbi":"","page":"38","recordref":"CL19-85","atlines":null,"is_chron":"1","RAG":"","textract":"Plaintiff hereby calls upon First Defendant and Second Defendant to furnish\nPlaintiff with all information at their disposal in order to assist Plaintiff to learn the\nfollowing information about Fourth Defendant:\n4.1.the most recent physical address known to First Defendant and Second\nDefendant where Fourth Defendant was or is doing business\nC 4.2.the most recent known contact details of Fourth Defendant, including email\naddresses, landline numbers, cell phone numbers and fax numbers","descrip":"Plaintiff Discovery Items 32 - 35 Mostly Emails","dated":"2020-02-19","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A28":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A28","c_note":"","noteMode":"DocNote","note":"Court Document : Sheriff served joinder application on Fourth Defendant","comment":"By this time, Fourth Defendant appears to already be out of business - premises locked and unattended","is_private":"0","docnum":"34","tbi":"","page":"41","recordref":"CL19-89","atlines":null,"is_chron":"1","RAG":"","textract":"That on the 13 December 2019 at 12h57 at 482B BOUNDARY ROAD, NORTHRIDING, RANDBURG being\nthe registered address of DRACO DEMOLITION CC, a copy of the Plaintiff's Notice to Joinder and Particulars\nof Claim ","descrip":"Plaintiff Discovery Items 32 - 35 Mostly Emails","dated":"2019-12-13","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A3":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A3","c_note":"","noteMode":"DocNote","note":"2nd Defendant : 2nd Defendant instructed 4th Defendant to build a temporary walkway and gave detailed specifications re its construction ","comment":"2nd Defendant was responsible for the safety of the scaffolding and could not abdicate responsibility by means of getting its subcontractor to erect it","is_private":"0","docnum":"75","tbi":"","page":"1","recordref":"0021-292","atlines":null,"is_chron":"1","RAG":"","textract":"","descrip":"2Nd Def Disc Item 14. 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Her pre-accident employment history also reflects further\n446 periods of unemployment.","descrip":"INDUSTRIAL PSYCHOLOGIST JOHN WAYNE REPORT","dated":"2013-01-01","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A32":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A32","c_note":"","noteMode":"DocNote","note":"Industrial Psychologist: Plaintiff is no longer suited to performing her pre-accident occupation","comment":"This means that she has suffered a future loss of income","is_private":"0","docnum":"82","tbi":"","page":"22","recordref":"","atlines":null,"is_chron":"0","RAG":"","textract":"Based on expert opinion, s no longer suited to performing employment as a\n476 domestic worker or as a cook, cleaner or general worker, for example, for reasons that appear\n477 to be related to the head injury sustained in the reported accident and the sequelae thereof.\n478 She is regarded as an unequal competitor in the open labour market for reasons that appear to\n479 be related to the head injury sustained in the reported accident and the sequelae thereof.","descrip":"INDUSTRIAL PSYCHOLOGIST JOHN WAYNE REPORT","dated":"2019-04-15","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A33":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A33","c_note":"","noteMode":"DocNote","note":"Plaintiff: Plaintiff suffers serious, disabling sequelae as listed here","comment":"This shows that Plaintiff's ability to work is seriously compromised","is_private":"0","docnum":"82","tbi":"","page":"12","recordref":"","atlines":null,"is_chron":"0","RAG":"","textract":"46 in the reported accident and the sequelae thereof:\n147 @ She has become withdrawn.\n148 She has developed memory problems.\n149 @ She fatigues easily.\n150 She suffers from headaches at her forehead.\n151 She can no longer walk long distances.\n152 @ She can no longer stand for prolonged periods.\n153\n154 The following complaints were mentioned upon direct questioning:\n155 She has difficulty concentrating.\n156 @ She has become short-tempered.\n157 She has become irritable.\n158 She has become aggressive.\n159 @ She suffers from depression.\n160 @ She has become nervous when travelling.\n161 She experiences bouts of dizziness.\n162 She has trouble sleeping in that she wakes up at night.\n163 @ She has nightmares related to the reported accident.","descrip":"INDUSTRIAL PSYCHOLOGIST JOHN WAYNE REPORT","dated":"2019-04-15","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A34":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A34","c_note":"","noteMode":"DocNote","note":"Medical Expert: OS Dr Oelofse says Plaintiff has suffered a soft tissue injury to the left calf","comment":"This suggests inability to do hard physical labour","is_private":"0","docnum":"82","tbi":"","page":"13","recordref":"","atlines":null,"is_chron":"0","RAG":"","textract":"Dr Oelofse states the following in his medico-legal report on page 14:\n177. Diagnosis :\n178 The claimant suffered a soft tissue injury to the left calf .","descrip":"INDUSTRIAL PSYCHOLOGIST JOHN WAYNE REPORT","dated":"2019-04-15","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A35":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A35","c_note":"","noteMode":"DocNote","note":"Medical Expert: Dr Oelfse says Plaintiff will always have some degree of impairment","comment":"This suggests permanently impaired earning capacity","is_private":"0","docnum":"82","tbi":"","page":"13","recordref":"","atlines":null,"is_chron":"0","RAG":"","textract":" She will always have some degree of impairment due to the pain and discomfort in her left\n183 leg as well as headaches .\n184","descrip":"INDUSTRIAL PSYCHOLOGIST JOHN WAYNE REPORT","dated":"2019-04-15","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A36":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A36","c_note":"","noteMode":"DocNote","note":"Case authority X v Y 1971 (1) SA 1 (A) para 40: Strict Liability is satisfactorily justified by the risk or danger theory","comment":"This principle justifies holding First Defendant liable for Plaintiff's injuries","is_private":"0","docnum":"83","tbi":"","page":"9","recordref":"","atlines":null,"is_chron":"0","RAG":"","textract":"[40] Strict liability is liability without fault. Although controversial, strict liability\nis satisfactorily justified by the risk or danger theory, which provides that\nwhere a person s conduct or activities causes a considerable increase\nin the risk of causing harm or damage, the person can be held liable for\ndamage ensuing even in the absence of fault.2 Determining whether an\nincrease of potential risk is considerable will depend on the legal\nconvictions of the community.","descrip":"1 Judgment X v Y re Public Policy Wrongfulness","dated":"1990-01-01","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A38":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A38","c_note":"","noteMode":"DocNote","note":"Judgment RvS: Wrongfulness typically acts as a brake on liability","comment":"","is_private":"0","docnum":"85","tbi":"","page":"25","recordref":"","atlines":null,"is_chron":"0","RAG":"green","textract":"20] Wrongfulness is an element of delictual liability. It functions to\ndetermine whether the infliction of culpably caused harm demands the\nimposition of liability or, conversely, whether the social, economic and\nothers costs are just too high to justify the use of the law of delict for the\nresolution of the particular issue. Wrongfulness typically acts as a brake\non liability, particularly in areas of the law of delict where it is undesirable\nor overly burdensome to impose liability.","descrip":"Judgment R v S re Wrongfullness Public Policy","dated":"2018-11-21","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A39":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A39","c_note":"","noteMode":"DocNote","note":"Judgment H v I : The hallmark of vicarious liability, then, is that it is based neither on any\nconduct by the defendant himself nor even on a breach of his own duty.","comment":"This is the basis whereon Second Defendant is liable for the wrongdoing of Fourth Defendant","is_private":"0","docnum":"88","tbi":"","page":"12","recordref":"","atlines":null,"is_chron":"0","RAG":"","textract":" The hallmark of vicarious liability, then, is that it is based neither on any\nconduct by the defendant himself nor even on a breach of his own duty.","descrip":"Judgment H v I Vicarious Liability","dated":"1980-06-01","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A40":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A40","c_note":"","noteMode":"DocNote","note":"Photo shows weak and wobbly scaffolding","comment":"This supports the proposition that the scaffolding fell down","is_private":"0","docnum":"35","tbi":"","page":"4","recordref":"","atlines":null,"is_chron":"0","RAG":"","textract":"","descrip":"Plaintiff Discovery Items 36 - 37 Photos","dated":"2016-02-08","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A41":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A41","c_note":"","noteMode":"DocNote","note":"Hospital Casualty report: Plaintiff sustained concussion due to a head injury","comment":"","is_private":"0","docnum":"46","tbi":"","page":"2","recordref":"","atlines":null,"is_chron":"0","RAG":"","textract":"","descrip":"1St&3Rd Def Discovery Item 6 Doctor`S Clinical Notes 20 Nov 2015","dated":"2015-11-20","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A42":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A42","c_note":"","noteMode":"DocNote","note":"Eye Witness: Arjeta Jahja arrived at scene immediately after the scaffolding had fallen on top of Plaintiff","comment":"This proves the causal nexus between the falling scaffolding and Plaintiff's injuries","is_private":"0","docnum":"38","tbi":"","page":"2","recordref":"","atlines":null,"is_chron":"0","RAG":"","textract":"| ran towards Entrance 1 and | had to jump over a pile of concrete to get to her, that was cleaned in\nthe next few minutes. She was in so much shock, she was shaking and crying. Herhead , clothes\nand shoes were full of dust, and her hand was injured. It was bleeding and a paramedic came,","descrip":"Plaintiff Discovery Items 56 - 58 Witness Statements","dated":"2019-06-06","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A44":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A44","c_note":"","noteMode":"DocNote","note":"Letter Pf Aty To 1st&3rd Def Aty: demands plea","comment":"This shows dilatoriness on Defendants' part","is_private":"0","docnum":"56","tbi":"","page":"1","recordref":"","atlines":null,"is_chron":"1","RAG":"","textract":"We confirm that we are not in possession of the First and Third Defendant's Plea\nherein. ","descrip":"1St&3Rd Def Discovery Item 16 Letter Pf Aty To 2Nd Def Aty 8 Nov 2018","dated":"2018-11-08","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A45":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A45","c_note":"","noteMode":"DocNote","note":"Medical Expert: IP evaluated plaintiff","comment":"This was the first examination","is_private":"0","docnum":"82","tbi":"","page":"1","recordref":"","atlines":null,"is_chron":"0","RAG":"","textract":"Medico-legal report for John Doe\n15 April 2019","descrip":"Industrial Psychologist John Wayne Report","dated":"2019-04-15","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A46":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"dorisgoodenough@gmail.com","note_num":"A46","c_note":"","noteMode":"DocNote","note":"plaintiff salary was R6169","comment":"","is_private":"0","docnum":"81","tbi":"","page":"1","recordref":"","atlines":"","is_chron":"1","RAG":"","textract":"TOTAL EARNINGS 9,829.50 TOTAL DEDUCTIONS 3,659.71\nNET PAY 0,00 6,169.79","descrip":"Salary Slip Plaintiff","dated":"2018-01-31","hidden":"0","xnote_num":"","xnotexcase_id":"","xdocnum":"","xdocxcase_id":""},"A48":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A48","c_note":"","noteMode":"DocNote","note":"Eye Witness: Branch manager arrived at scene immediately after scaffolding fell and saw prrtion of ceiling on top of Plaintiff","comment":"This proves causation of the injury","is_private":"0","docnum":"38","tbi":"","page":"1","recordref":"CL19-25","atlines":null,"is_chron":"1","RAG":"","textract":"","descrip":"Plaintiff Discovery Items 56 - 58 Witness Statements","dated":"2015-10-27","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A5":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A5","c_note":"","noteMode":"DocNote","note":"2nd Defendant : on 6 June 2015, 2nd Defendant received formal handover of the scaffolding","comment":"2nd Defendant was r in control of the scaffolding once handover had taken place ","is_private":"0","docnum":"74","tbi":"","page":"1","recordref":"CL21-291","atlines":null,"is_chron":"1","RAG":"","textract":"","descrip":"2Nd Def Disc Item 13. Scaffold - Handed Over - Safe To Use Sign","dated":"2015-06-06","hidden":"0","xnote_num":null,"xnotexcase_id":null,"xdocnum":null,"xdocxcase_id":null},"A50":{"case_id":"9-8","case_team_id":"1","authorAlpha":"A","team_member_email":"","note_num":"A50","c_note":"","noteMode":"DocNote","note":"Document Evidence: Doctor prescribed strong painkillers.","comment":"This proves that Plaintiff suffered severe pain. 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