While attending a car show at Oak Grove Regional Park, Plaintiff David Marquez (“Plaintiff”)
was injured when he stepped into a hole at the base of a pillar pole bordering a handicapped
parking spot. (UMFs 1–5.) Defendant County of San Joaquin (“Defendant”) owns and
maintains Oak Grove Regional Park (the “Park”) in Stockton, California. (UMF 2.) As the
owner of the Park, Plaintiff argues that Defendant is liable for the injuries he sustained as a
result of the dangerous condition on the public property. (UMFs 3–4.) Plaintiff argues that one
of the responsibilities Defendant is to keep the park in a safe condition and to perform
inspections for unsafe conditions.

On November 25, 2019, Defendant filed the instant motion for summary judgment, or in the
alternative, summary adjudication of the following issues:

1. Plaintiff cannot make a recovery on the Complaint because there was not dangerous
condition of public property.
2. Plaintiff cannot prove that the condition he alleges caused