Our client, a 44-year-old fireproofer, was working at a warehouse where he was responsible for spraying cement-like material from a pump and hose apparatus while standing on a mobile scaffold eight feet from the floor. When a new area needed to be sprayed, the scaffold was pushed around the warehouse while he stood upon it. He claimed that his co-worker suddenly moved the scaffold, throwing him off of it. There were no guardrails and he was not given a safety belt which violated labor laws. The fall resulted in a subarachnoid hemorrhage of the brain, permanent disability from ongoing migraine headaches, as well as an internal derangement of the left shoulder which required arthroscopic decompression surgery. These injuries left him unable to return to work as a laborer. The case settled for $1,200,000 to cover past and future lost earnings, medical expenses as well as benefits.