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Complaint - Negligent Asphalt Work at Job Site

IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA

CASE NO. xx-xxxx-xx

THOMAS D. and MICHELLE D.,
  Plaintiffs,

  vs.

SMITH & COMPANY, INC.,
  Defendant.
__________________________________/

COMPLAINT

The Plaintiffs, THOMAS D. and MICHELLE D., sue the Defendant,  SMITH & COMPANY, INC.,and allege:

1.  This is an action for damages in excess of $15,000.00, exclusive of interest, costs and attorney’s fees.

COUNT I – NEGLIGENCE AGAINST SMITH & COMPANY, INC.

2.  On or about June 22, 1999, Plaintiff, THOMAS D., was working at the construction site located at 15977 Pines Boulevard, Pembroke Pines, Broward County, Florida, known as the Westfork Plaza.

3.   Defendant, SMITH & COMPANY, INC., was a sub-contractor at that job site and had the responsibility to perform the asphalt work.

4.   Defendant was negligent in performing asphalt work at the construction site causing Plaintiff, THOMAS D., to step into a hole or depressed area and fall in that:

      a.   Defendant failed to fill in a hole or depressed area in the vicinity of a  shut-off valve.

5.    As a result of the Defendant’s negligence, Plaintiff, THOMAS D., sustained permanent bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of ability to earn money, and/or aggravation of a previously existing condition.   As the injuries are permanent, Plaintiff will continue to suffer damages in the future.

6.    As of June 22, 1999, Plaintiffs were married to each other.

7.    As a result of the Defendant’s negligence, MICHELLE D., lost the comfort, society, attentions and services of her husband in the past and will continue to do so in the future.  

WHEREFORE Plaintiffs demand judgment for compensatory damages against the Defendant and further demand a trial by jury of all issues so triable.

LAW OFFICE OF ALAN D. SACKRIN
Slip and Fall Attorney
Attorney for Plaintiff
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649
www.Hallandalelaw.com

By: _________________________

ALAN D. SACKRIN
Florida Bar No. 349070


This is a sample lawsuit related to a specific set of facts and circumstances and should not be used or relied upon if you have been in a slip and fall accident.  We recommend and urge you to consult with an experienced slip and fall lawyer for professional advice as each case is unique.

 

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