Motion to Dismiss 003-duty to mitigate ice and snow-premises

Response to Motion to Dismiss in natural accumulation of ice and snow case, setting up appeal to Oklahoma Supreme Court (OK Supreme Court 004 and 005) asking Court to align Oklahoma with states requiring mitigation of natural ice and snow to remedy the defect.

Analysis of historic legal rules and cases in claims from several states over whether premises owner owed duty to invitees with regard to natural accumulations of ice and snow.

Analysis of cases where plaintiff knew of danger but made recovery anyway.

Oklahoma should follow Connecticut Rule, as it will accord with most jurisdictions, restatement, and recent developments in Oklahoma tort laws.