Slip & Fall cases require experience. Defendants will seek to defend claim because any hazard (crack in sidewalk, spilled liquid) is “open and obvious hazard”.
Similarly, Defense will typically assert Contributory Negligence of the person bringing the claim. I have had success utilizing discovery to show that Defendants did not take care of property or follow procedures required. In particular, a major carpet cleaning company settled when my client’s injuries were caused by “new hire” who did not warn and take safety measures required.