Plaintiff vacated the Apartment in 2006, spending 2006 through 2007 mostly in
Shanghai, China partly for work as a brand director and partly "because — what
was happening in my apartment, I thought maybe this is a good opportunity to get out of
the way of the problem, report it and let them take care of it" (Ct Exh 4A ¶
21[b][1], 4/20 32:21-23, 38:1-3).[FN7]
Upon Plaintiff's return from China in 2008, she resided either with her mother in
Watertown, [*4]Connecticut or apartment PHC, next to
the subject Apartment (5/7 906:5-8, 907:9-16, 950:2-4, 951:12-22)[FN8]
. In 2014, Plaintiff lived in Stratford, Connecticut (5/7 991:18-20). In 2015,
Plaintiff lived at a different Stratford address (5/7 974:2-14, 991:14-17). Even
during her time not residing full-time in the Apartment, and particularly during her time
in PHC, Plaintiff monitored the Apartment's condition, appliances, and fixtures (5/7
950:2-4, 951:12-22, 990:18-991:14, 992:25-993:19).
Though Plaintiff did not personally witness every instance of infiltration, she
deduced their origins, in part, from the observable aftermath: for example, rust in the
ceiling fixtures, water-damaged books and lights, stains, swollen walls and floors, and
mold (4/20 36:20-37:6, 74:9-15, 5/7 958:20-962:18, 969:17-24). From
these observations, she determined—credibly— that the water originated
from several locations outside of the Apartment: the ceiling, the terrace, and the HVAC
system (4/20 36:14-37:6, 74:6-76:8, Pl Exhs 5, 5A).[FN9]
The water damaged the Apartment's wood floors, appliances, furniture, and many of
Plaintiff's personal items (4/20 40, et seq.; see e.g. Pl Exh 30).
Work on repairing the HVAC unit, performed by the dismissed Third-Party
Defendants, began in the fall of 2007 and spanned to 2009 (4/20 80:14, 81:1-12,