Sean Genrich v. Allied Studios, et al.

Case Background

Sean Genrich filed a product liability lawsuit alleging negligence after a defective forklift on a filming set caused severe injuries. The lawsuit was filed in the California Superior Court, Los Angeles County. Judges Mary Ann Murphy, Lee S. Arian, and Lisa R. Jaskol presided over this lawsuit. [Case number: 21STCV36709]

Cause

Defendants Allied Studios, Allied Partners LLC, and Does 1 through 50 owned, managed, and were responsible for the commercial property at 6800 Smith Road, Simi Valley, California (referred to as the “Premises”). Allied Studios, located in Simi Valley, served as a movie and television production facility. It provided various indoor and outdoor filming locations, along with additional production support services. One of these services included renting forklifts to production companies and their staff. Defendant Dependable Lift, LLC sold, rented, and repaired forklifts. Doe 1 was later identified as Pacific Studio Rentals Inc., and Doe 2 was identified as LLP Production Services Inc.

On or around June 21, 2021, Plaintiff Sean Genrich, a production designer, worked for a production company filming at Allied Studios. Defendants provided Genrich and the company with a forklift for use on set. It was believed that Dependable Lift, LLC owned, rented, repaired, and maintained the forklift involved in the incident.

Genrich, who had experience operating forklifts, was instructed to use the forklift to move equipment. While adjusting the forks to the appropriate width for the task, the entire fork mechanism unexpectedly fell, landing on Genrich’s right foot and causing an injury.

Genrich claims that the forklift was in a defective and dangerous condition when it fell. He asserts that improper maintenance, inspection, and failure to provide adequate warnings allowed this hazardous condition to exist and lead to the injury.

Injury

Plaintiff suffered severe injuries to his foot and toes. As a direct result of the Defendants’ negligence, Plaintiff experienced harm to his health, strength, and ability to perform daily activities. He sustained bodily injury, shock, and damage to his nervous system.

Damages

As a result of these injuries, Plaintiff suffered general damages. Due to the actions of the Defendants, Plaintiff incurred and will continue to incur, expenses for treating his physical injuries. The full extent of these damages will be proven at trial. Furthermore, as a result of the Defendants’ conduct, Plaintiff was unable to perform his usual work. This caused a loss of income and reduced earning potential.

Key Arguments and Proceedings

Legal Representation

  • Plaintiff(s): Sean Genrich
    • Counsel for Plaintiff(s): Matthew B.F. Biren | Andrew G. O. Biren | John A. Roberts | Spencer N. Goldberg
  • Defendant(s):  Allied Studios | Allied Partners LLC | Dependable Lift, LLC | Pacific Studio Rentals Inc. | LLP Production Services Inc. | Watch This Production! LLC
    • Counsel for Defendant(s): Rivera Diana | Evan A. Berman | Farrell C. Covell | Heather L. Mills | Richard S. McGuire | Arlene N. Olson

Claims

First Cause of Action: Negligence
Defendants owned, operated, rented, leased, maintained, inspected, and controlled the forklift carelessly and negligently. As a result, the forklift became defective and dangerous. While being adjusted, the entire fork mechanism fell and landed on the plaintiff’s foot. Defendants knew or should have known through reasonable care, that the forklift’s dangerous condition created an unreasonable risk of injury. They should have been aware that the forklift was likely to malfunction and cause harm.

The incident occurred due to the negligent actions of the defendants.

Second Cause of Action: Strict Products Liability
On or around the date of the incident, Plaintiff’s employer borrowed or leased a forklift from the defendants. Defendants knew and intended for the forklift to be used by the production company’s employees to move heavy equipment on-site.

Plaintiff alleged that the forklift was defective and unsafe for its intended use when it was provided to his employer.

Cross-Complaints

Allied Partner LLC filed a cross-complaint against Watch This Production! LLC. The complaint stated that Pacific Studio Rentals, Inc. had contracted with Watch This, which agreed to indemnify and defend the licensor from any third-party claims related to the licensed area, including claims from employees, contractors, and others involved in the production.

As a third-party beneficiary of this contract, Allied Partners sought defense and indemnity from the cross-defendants. They argued that any liability was passive and secondary, resulting from the actions of the cross-defendants.

Allied Partners demanded the cross-defendants fulfill their defense and indemnity obligations, but they failed to comply. Allied Partners requested full indemnity for any costs, attorney’s fees, and expert fees incurred while defending against the plaintiff’s claims. These costs were expected to increase as the trial continued.

Additionally, Allied Partners filed for implied indemnity, denying responsibility for any damages in the plaintiff’s claims. They contended that any fault attributed to them would stem from the primary negligence of the cross-defendants.

Dependable Lift, Inc. also filed a cross-complaint, alleging that the cross-defendants, identified as ROES 1 to 50, were responsible for the plaintiff’s injuries. Some cross-defendants remained unidentified but would be added once known.

Defense

Cross-Defendant Watch This Production! LLC denied all allegations in the cross-complaint and claimed that the Cross-Complainant (Allied Partner) suffered no damages due to its actions. The defense asserted that the Cross-Complainant’s recovery was barred by its negligence, or, if the Cross-Defendant contributed, recovery should have been reduced based on comparative negligence. Additionally, the Cross-Defendant argued that any damages were caused by others’ negligence and that the cross-complaint failed to state a valid cause of action.

Defendants Pacific Studio Rentals, Inc., and LLP Production Services, Inc., denied all allegations in Plaintiff Sean Genrich’s complaint. They argued that the statute of limitations barred the suit and that it failed to state a valid cause of action. They claimed that third parties or Plaintiff’s own negligence and failure to mitigate caused the injuries. Defendants also contended that Plaintiff assumed the risks and ignored product warnings, which contributed to the damages. They asserted that modifications to the product caused the injury. Defendants reserved the right to amend their response if needed.

Before trial, the court dismissed Allied Studios, Allied Partners, Dependable Lift, and LLP Production Services, Inc.

Jury Verdict

On July 3, 2024, the jury found that Pacific Studio Rentals was negligent in renting out the forklift and such negligence was a substantial factor in causing Plaintiff Sean Genrich harm.  No negligence on Genrich’s part was found. The jury determined that Watch This Production! LLC’s negligence was a substantial cause of Genrich’s harm. The jury allocated 80% of the responsibility for Genrich’s harm to Pacific Studio Rentals and 20% to Watch This Production!

The jury awarded the following in damages:

  • Economic Loss: $610,000
    • Past economic damages (Lost earnings): $150,000
    • Future economic loss: $460,000
      • Medical expenses – $29,000
      • Lost earnings – $431,000
  • Non-economic Loss: $300,000
    • Past non-economic loss: $222,000
    • Future non-economic loss: $78,000

The total verdict awarded was $910,000.

Court Documents:

Documents are available for purchase upon request at jurimatic@exlitem.com