Plaintiff was walking to her place of employment at a strip mall in Indiana, where she alleged that she tripped and fell on rocks that were displaced from a large decorative rock bed. Plaintiff sued the business and property owner alleging negligence and premises liability counts. Brian Brenn took up defense of the property owner, and was skeptical of the circumstances of the fall. He aimed to set the case up for a motion for summary judgment and took multiple depositions with this in mind.