Max Billek (Partner-New Jersey) and Elyse Schindel (Associate-New Jersey) represented a security company against which the plaintiff filed a Complaint in Superior Court, Bergen County, NJ, alleging that our client was negligent in performing its duties at an apartment complex. The plaintiff was assaulted in the parking lot of the complex by individuals he knew. Max and Elyse established that the plaintiff was in fact lured out of his apartment by a friend, and was later struck with a baseball bat by another individual, also known to him, over a relationship dispute. The plaintiff suffered serious head trauma and underwent emergency bilateral decompressive craniotomy and evacuation of bilateral epidural hematomas. He was diagnosed with traumatic brain injury with residual somatic, cognitive and emotional sequela; post-traumatic headache disorder; and trauma to the neck and back resulting in cervical, thoracic and lumbar spine injury. The claim for economic and noneconomic damages was considerable as plaintiff’s medical bills alone were in excess of $200,000. The matter could not be resolved and Max and Elyse moved for summary judgment before trial. The motion was argued by Elyse, and the court agreed that our client did not breach any duty to the plaintiff, as the security company was performing its contracted-for security services on the date of the incident. The court also agreed with our position that this preplanned incident was not foreseeable to our client. The court accepted our position that the plaintiff did not carry his burden of demonstrating that the defendant was or should have been aware of significant past criminal incidents and/or other indices of a dangerous condition to establish notice to the defendant. Accordingly, the judge granted summary judgment in our favor.