4696            REHEARING GRANTED  Three previous incidents of sudden, unprovoked, increasingly violent assaults on people in ungated parking areas on the premises by strangers in the middle of the night, all causing great bodily injury -- one of which involved use of a knife, another of which was a robbery committed by hitting the victim over the head as he got out of his car, and the third involving what the police report characterized only as a deadly weapon -- were found as a matter of law to be sufficiently similar to a gunman's attack on plaintiff to meet the relatively low level of foreseeability required to impose on defendant the relatively low burden of fencing and gating the small parking lot.

TAN v ARNEL MANAGEMENT (Ungated Parking Lot) 162 CA4 621 [See: 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]