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Chang v. Fine Discount No. 1, Inc. CA2/8
Plaintiff Eunhee Chang’s retail store caught ablaze after a fire of unknown origin started at the neighboring warehouse operated by defendant Fine Discount No. 1. The fire reduced both businesses to roofless, crumbling structures filled with debris. Plaintiff sued defendant for negligence both in starting the fire and in causing the fire to spread to her building. The court granted nonsuit on the first cause of action for starting the fire and the jury found in favor of defendant on the second cause of action.
Plaintiff appeals from the judgment arguing that the court erred in granting nonsuit as to her first cause of action. Plaintiff also asserts the court erred by preventing her from pursuing a negligence per se theory of liability on the second cause of action. Finally, she contends the court abused its discretion in admitting photographic evidence and a declaration by defendant’s counsel about costs. We affirm on all grounds.

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