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4850 REVIEW DENIED Three incidents of violence committed by third persons in the ungated parking lot of defendant's apartment complex prior to an attempted carjacking and shooting of plaintiff, who was a tenant in the complex, were sufficiently similar to the attack on plaintiff to meet the low level of foreseeability required to impose a duty to take minor and unburdensome precautions, such as erecting a gate and a short length of fence.CitationTAN v ARNEL MANAGEMENT (Ungated Parking Lot) 170 CA4 1087 [See: Tan v Arnel (RevGrtd) 162 CA4 621, T/AT 6/08; Ann M v Pacific Plaza 6 C4 666, T/AT 2/94; Sharon P v Arman 21 C4 1181, T/AT 1/00; Delgado v Trax 36 C4 224, T/AT 8/05; Castaneda v Olsher 41 C4 1205, T/AT 9/07; Claxton v ARCO 108 CA4 327, T/AT 6/03]
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