In Sanchez v. Bally's Total Fitness Corp. (1998) 68 Cal.App.4th 62, an adult woman sued her health club for negligence because of injuries she sustained when she fell while crossing over a "slide" aerobics mat. The Sanchez plaintiff alleged she was not adequately trained on how to safely cross over the mat. Her membership agreement contained a release clause which stated, among other things, that the member "'"agrees that all exercises and use of the fitness centers are undertaken by the member at the sole risk of the member, and that the fitness center shall not be liable for any claims for injuries and damages whatsoever to person or property of the member or of a guest of a member arising out of or connected with the use of the fitness center. Member agrees to indemnify and to hold the center and its employees harmless from all claims by or liability to member or member's guest, except for claims arising out of the center's knowingly failing to correct a dangerous situation brought to its attention."'" ( Id. at p. 68.) The Sanchez plaintiff admitted that she read and signed this release when she became a member and that she understood its content but she argued the release was invalid as a matter of law because it did not contain the word "negligence." ( Sanchez, supra, 68 Cal.App.4th at. at p. 67.) The Sanchez court rejected this contention and focused instead on the language of the release in order to determine the intention of the parties. The court found that the clear and unambiguous terms of the release expressly extended to any claims for injuries or damages arising out of or connected with the use of the health club. Furthermore, the plaintiff's specific injury, though not expressly contemplated in the release, was covered by the terms of the release because it was an injury "'arising out of or connected with the use of the fitness center.'" ( Id. at p. 69.) In Sanchez v. Bally's Total Fitness Corp. (1998) a health club patron was injured while using fitness equipment. She had previously signed a release for fitness-related injuries she suffered at the health club. Sanchez contended the release was ineffective in that it did not expressly refer to the negligence of Bally's Total Fitness. The Sanchez court held that the release was applicable by its terms and context to the negligence of Bally's Total Fitness. In the course of its discussion, the Sanchez court referred to Leon v. Family Fitness Center (# 107), Inc. (1998). The Sanchez court noted that the release in Leon had been fitness related and the sauna bench collapse causing injury to Leon had "occurred as a result of an incident not reasonably contemplated by the parties." (Id. at p. 67.) In discussing whether the negligence of Bally's Total Fitness causing injury to Sanchez was within the scope of the fitness-related release that Sanchez had signed, the Sanchez court stated: "It is obvious that patrons of health clubs sign release and assumption of risk provisions in contemplation of injuries that occur in the course of using the facilities for the primary purpose of exercising and using exercise equipment. Therefore, the injury suffered by plaintiff in the present matter is one reasonably within the contemplation of the parties." (Id. at p. 68.) The Sanchez court determined the scope of the release in its case by examining the language of the release. In Sanchez v. Bally's Total Fitness Corp. (1998) the agreement signed by the plaintiff in that case stated in part: "The member agrees that all exercises and use of the fitness centers are undertaken by the member at the sole risk of the member, and that the fitness center shall not be liable for any claims for injuries or damages whatsoever to person or property of the member . . . arising out of or connected with the use of the fitness center." The plaintiff's injury occurred as a result of her participation in a slide aerobics class. The class involved the use of an extremely slippery mat on which the participant slides from side to side as an aerobic exercise; special socks are worn to facilitate sliding on the mat. The plaintiff in Sanchez was injured when she attempted to walk across the mat. She slipped and injured her wrist, and asserted that had she received instruction on how to cross the slide mat, the accident would not have happened. She argued the general release clause should not relieve the defendant of liability as a matter of law because it was not set out in large or italicized letters and did not include the word negligence. The court rejected the whole of the plaintiff's argument, and noted that the plaintiff's injury was "reasonably within the contemplation of the parties" (Sanchez, supra, 68 Cal.App.4th at p. 68). The court reviewed a line of cases that had found release provisions ineffective where they did not expressly waive the defendants' "negligence." However, the Sanchez court found the holding in those cases did not turn on the mere absence of the term negligence. Rather, "the fundamental predicate for their holding is that the exculpatory provisions were not clear, unambiguous, or comprehensible or were formatted so as to obscure their inclusion in the agreements." ( Id. at pp. 66-67.) In Sanchez, notwithstanding the absence of a specific reference to the defendant's "negligence" with regard to the operation of its health club facility, the court held plaintiff's injury (a fall suffered during an exercise class due to defendant's allegedly negligent instruction) was precisely the sort of "injury . . . arising out of or connected with her] use of the fitness center" for which she had expressly agreed to hold defendant harmless. ( Id. at pp. 68-69.)