Valerie Dondero, of our Miami office, obtained a Summary Final Judgment in favor of a prominent hotel chain after brief discovery indicated the Hotel did not control or direct the method by which an independent contractor performed dangerous work on its premises. The Plaintiff sued the Hotel and a product’s manufacturer when he fell from a ladder while performing window washing services at the Hotel. The Plaintiff claimed to have sustained a massive brain injury, leaving him disabled from work and everyday activities, with millions of dollars claimed for long term care and treatment for the remainder of Plaintiff’s life. Valerie successfully argued Florida law that exculpates a property owner from liability for injuries sustained on its premises by independent contractors who are engaged in the dangerous work which they were hired to perform. Valerie was able to prove the Hotel did not maintain any control over the method by which the independent contractor performed the work, and did not direct or supervise the window washing activity. The Summary Final Judgment was entered without extensive discovery or depositions and extinguished the Hotel’s exposure for significant damages and defense costs.