This case involves a man who was injured while painting the walls of a self-described “sustainable urban lifestyle” retail store. He and his company had been hired as a sub-contractor to paint the store, which was undergoing extensive renovations to install solar panels and make the entire retail operation energy independent. While painting the store, several of the steel shelving units collapsed on the man. It is alleged that when these shelves were moved by employees of the retail store or other contractors, they were never inspected to ensure adequate safety and lock-in mechanisms. The shelves were not properly fastened and when they collapsed on the painter they caused significant injury. The plaintiff requires an expert who has formerly served as a manager or safety manager of a large, big box retail store.