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4695 Even under the regular foreseeability standard, prior incidents consisting of trespasses on defendant's premises by a few nonthreatening transients were not sufficiently similar to an assault that occurred in defendant's parking lot to make the assault foreseeable, so defendant had no duty to employ even minimal safety precautions.
ERICSON v FEDERAL EXPRESS (Heightened Foreseeability) 162 CA4 1291 [See: Ann M v Pacific Plaza Shopping Center 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]
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