Kentucky's slip and fall law is in a bit of flux as to what is called the "open and obvious" doctrine. This doctrine essentially provides that if a hazard is something that should have been seen and avoided, then there is no liability.
Slip and fall cases are extremely fact specific. Do you have photos of the scene? If not, then can you take photos? Please include a ruler in the photo to show the height of the manhole cover. Take some close-up and distance photos.
We would be happy to review the photos with you once you have them.
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