EDWARDSVILLE – A guest at the Edwardsville home of late asbestos lawyer Randy Gori - whom he never met - had a dispute over his liability for injuries she suffered in his pool, according to testimony of plaintiff Sara Staack and nearest witness Tatiana Del Valle.
Randy Gori's estate administrator and former wife Beth Gori attached their depositions to a motion for summary judgment against Staack on Aug. 11.
They testified that Randy Gori allowed friend Andre Davila to invite his friends to Gori’s home on Mooney Creek Road while he was away.
Davila invited Staack, Del Valle, and Kayla Grass to the home on July 19, 2019.
Del Valle had visited before and Staack hadn’t.
They arrived after 10 p.m. and found several guests they didn’t know.
Davila took Staack, Del Valle, and Grass on a tour and led them out through the kitchen.
Del Valle and Grass sat in the pool area and Staack explored.
Del Valle testified, “Out of the corner of my eye I saw her disappear.”
She said she thought Staack jumped into the pool.
Del Valle said she told Grass and Davila she thought Staack fell, and she got up and ran.
She said she looked over a rail and saw Staack below.
“I went to touch her face, like to have her look at me,” she said.
“That’s when I felt that this was open,” she said, pointing under her chin.
Del Valle said one of the guests shined his flashlight on Staack.
“We could see that it was all, like all, down her face and her shirt,” she said.
“She couldn’t walk because it was pretty much the whole left side of her,” she added.
Del Valle said she imagined Staack stepped into a waterfall and the current swept her feet.
She said they carried Staack to her car and took her to Anderson Hospital but had to return to get her wallet.
Del Valle said she told Andre that Staack was at the hospital and possibly broke her arm. Staack testified that she broke her radius below the elbow.
Staack’s counsel Lanny Darr of Alton asked Del Valle if someone tried to get Staack to accept money from somebody.
Del Valle said, “I tried to stay super neutral because Andre and Randy were my friends and Kayla and Sara were my friends.”
“I’ve actually felt extremely responsible for the entire thing because I brought her there, I took her to the hospital, but I didn’t want to instigate any conflict,” she said.
“I just felt really awkward because as much as I felt like she did injure herself, I personally, even though Randy had a ton of money, I personally felt like she was trying to take advantage of the whole situation,” she added.
“Kayla was the one who basically suggested that Sara sue Randy,” she continued.
Darr asked if she remembered the conversation, and she said it was in the hospital.
Del Valle said Staack had kind of an anxiety attack because it was her weekend for Army Reserves and she’d get in trouble for not reporting.
She added that Staack was a server, and it was her serving arm that was injured.
She said that was when Grass said she should sue Gori.
“Me and Kayla had a conversation about it because Kayla felt very strongly that Sara deserved money from Randy,” she said.
“If I had to choose sides, it would have been Randy and Andre,” Del Valle added.
“What made her think she could walk across an infinity pool that had a waterfall?” she continued.
Del Valle said Davila later found out Staack hired a lawyer for arbitration.
She said Davila told her it would be about $2,500.
“When Andre told me that I offered to pay Randy that money because I felt extremely responsible for everything that happened,” she said.
Del Valle said she called Gori and asked when she could meet him to give him the money.
“Randy said oh, is that what we agreed on?” she said.
“I said well, that’s what Andre just said,” she added.
“He goes, I haven’t agreed to anything yet,” she continued.
Beth Gori’s counsel Chris Dallavo of Chicago asked Del Valle to explain her testimony that Staack and Grass grew angry at each other in Gori’s house.
Del Valle said Grass discovered she had different political beliefs than Gori and said she would not work for him after previously planning to do a criminal justice internship at Gori's firm.
She said they got into a huge argument and are no longer in contact..
“Yeah, we don’t have a relationship because of this situation,” she said.
“She went Sara’s side, I went Randy’s side,” she added.
Dallavo asked Del Valle if she stayed in touch with Staack, and Del Valle said, “I have no relationship with either of them.”
At Staack’s deposition, Dallavo asked if it was correct that she never met Gori.
She said it was correct but said she spoke with him after she fell.
He asked when, and she said a day later.
She said he asked if she was OK, and she told him what happened.
Dallavo asked if he called her or she called him, and she said, “I contacted him.”
He asked how she got his contact information, and she said Facebook.
He asked if she preserved a copy, and she said, “I don’t have Facebook anymore, so no.”
She said she, Del Valle, and Grass first went to a party at a St. Louis hotel where she drank two White Claws.
Davallo asked if she was 100% sober at Gori’s residence, and she said yes.
“Andre gave us the tour of the house and then we talked a little bit in the kitchen, and then we walked outside by the fire pit,” she said.
“I thought you could walk around the pool but you couldn’t. It was just a drop off,” she added.
“I just kept walking straight, and I just fell into like blackness,” she continued.
Dallavo asked if anything at the back of the pool alerted her to the fact that the pool was ending.
“I guess the light of the pool was ending. Like the water was ending, so yes,” Staack said.
Staack said her left elbow hit first but she also thought she broke her leg.
He asked about pain and she said, “It just felt like my whole head was hurting. My whole body was really hurting.”
She said she slept at Grass' house and felt worse the next day.
“I couldn’t even move, and I felt very nauseous as well,” she said.
Staack said Grass and her mother took her to St. Elizabath’s hospital, where they did a head scan and gave her nausea medicine.
She added that Associated Physicians did therapy on her neck and back, and she felt a lot better.
Davallo asked about her left leg and she said, “I can walk fine.”
She said there was discoloration from scrapes, “but it doesn’t like ruin my day every day.”
He asked about her left elbow, and she said, “When I drive, sometimes it feels a little bit weird and it clicks a little bit but that’s pretty much it.”
He asked about her left hand, and she said, “It pops and it feels like it needs to be adjusted a little bit.”
Staack said it happens maybe once a day.
Davallo asked if she did anything for it, and she said, “I just readjust my arm or maybe switch arms.”
He asked about activities that her injuries affected, and she said, “I just don’t pick up my kid with this side.”
“Carrying groceries and stuff like that, I don’t get all of them at once,” she said.
Davallo told her that her complaint alleged a dangerous condition, and he asked what it was.
She responded, “Lack of light and lack of something separating me from walking up.”
Davallo asked if she wanted to tell him anything, and she said, “Hitting my head that hard kind of worried me, like it might have long term effects.”
He asked for anything else, and she said, “When I hit my head I developed tinnitus, like ringing in my ears, but I haven’t gone to the doctor.”
Dallavo argued in Beth Gori’s motion for summary judgment that the danger of the pool was open and obvious.
He claimed Staack knew she was at the end of the pool and the sound of water running over the edge of the pool was audible.
Associate Judge Ronald Foster set a hearing on the motion for Aug. 17.
Lanny Darr no longer represents Staack and no one has entered an appearance as her counsel.
The court sent its last correspondence to her at a vacant building in Freeburg.
Nothing in the docket indicates she received notice of the hearing.