New resident of an apartment complex fell when her foot became wedged in a hole in the common area of the property. As a result of her fall, plaintiff sustained bilateral injuries to her wrists, knees, ankles, and back. The defendant argued that they had no notice of the hole in the property and that they have no duty to warn of conditions unknown to them. Our office issued a subpoena to their landscaping company which revealed the complex was aware of other holes on the property days before the plaintiff's fall. Defendant filed a motion for summary judgment based on lack of notice, but the judge denied the defendant's motion in large part because of the landscaping document obtained by subpoena. A pretrial conference was held with the motion judge in Cook County.