I have always been fascinated with the concept of foreseeability and how it applies to cases in which crimes occur on premises.  Kings County Supreme Court Justice Knipel in this recent case, Bouraee v. Lutheran Med. Ctr., held that the attack on a vascular surgeon inside a hospital elevator was not foreseeable.  The case is a good one to demonstrate what type of evidence is necessary to demonstrate that the premises owner had notice of similar criminal activity prior to the subject attack.