Con owns a medium$-$sized restaurant in a relatively safe neighborhood. The restaurant has a parking lot directly next to the building. The parking lot is well lit.

One night, after dining at Con's, Leon was walking back to his car when someone snuck up from behind and hit him in the head with a tree branch. Leon was knocked out and the person took his wallet and smartphone. Leon was in great pain for several weeks and suffered severe physical injuries. The person who robbed Leon had no association with Con or the restaurant. Indeed, this was the first time such an incident had occurred at Con's.

Leon sues Con for negligence and seeks damages for doctor's bills, pain and suffering, and punitive damages.

Which of the following would be Con's best defense against the lawsuit?

Question $1$Select one or more:

a$.$

We are never responsible in tort for the acts of third parties

b$.$

You cannot recover pain and suffering damages because they are too hard to calculate

c$.$

Con did not intend any harm to Leon and therefore could not have committed a tort

d$.$

Con was not the proximate cause of Leon's injury because it was caused by an unforeseeable third party action