3192 DEPUBLISHED Although the general rule is that a landlord has no duty to install window screens or take other steps to prevent a child from falling from a window in an apartment in which the child resides, such a duty may exist when the landlord has expressly covenanted to do so.CitationWHITE v CONTRERAS (Window Screen) 93CA4 137 [See: Rowland v Christian 69 C2 108; Ballard v Uribe 41 C3 564; Amos v Alpha 73 CA4 895, T/AT 9/99; Pineda v Ennabe 61 CA4 1403, T/AT 4/98; Paz v State 22 C4 550, T/AT 4/00]
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