Abstract: At approximately 9:00 a.m. on June 29, 2005, Employee #1, a construction laborer, was working under supervision of two supervisors at the construction site located in San Diego, California. Employee #1 attempted to climb up two vertical bundles of stacked Simon forms. The bundles were stacked in sets of nine forms each, called panels, and were approximately 49-in. high, 6-ft long, 3-ft wide, and weighed approximately 500 lbs. One bundle of nine forms, which was at the bottom, was stacked on top of another bundle of nine panels, for a total height of 98 in. from the top of a flatbed truck to the top edge of the 18th panel. The distance from the pavement to the top of the flatbed truck was 36 in. Employee #1 was rigging up a sling around the top bundle, so a crane could remove the top bundle from the flatbed truck. Employee #1 was climbing up the side of the two vertical bundles, which were made of 18 panels stacked on top of each other. He was stepping on the edge of the panels with his feet and pulling himself up with his hands on the bands that surrounded the bundled forms. When Employee #1 was pulling himself up over the 9th panel of the second vertical stacked bundle, the banded bundle of panels shifted towards him. Employee #1 fell backwards 6 to 7 ft to the pavement. The edge of one of the panels from the top vertically stacked bundle fell on Employee #1 causing a severe laceration of the tendon and ligament, all the way to the bone, above his right knee. Employee #1 was transported to the Scripps Mercy Hospital. He had a surgery and was hospitalized.