Faulty Chair Complaint-Department Store Negligence

IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND
FOR MIAMI DADE COUNTY FLORIDA

CASE NUMBER:   05-XXXXXX CA (31)
        
TB,

Plaintiff,
         vs.
         
BURDINES, INC.,
         
Defendant.
_________________________/

AMENDED COMPLAINT

The Plaintiff, TB, sue the Defendant, BURDINES, INC., and alleges:

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

2.    On or about March 14, 2002, Defendant owned and/or operated a Burdines Department Store located at the Broward Mall, 8000 W. Broward Blvd , Fort Lauderdale, Florida, in Broward County, Florida.

3.     At that time and place, Plaintiff went on to Defendant’s premises to shop.

4.    While in Defendant’s store, Plaintiff sat in a chair which was provided for her use when it broke or collapsed causing Plaintiff to fall.

5.    Defendant, through its employees, was negligent in causing the subject incident in that: (a) Defendant failed to remove the chair which Defendant knew or should have known was broken or otherwise in a defective condition; and (b) Defendant failed to inspect or maintain the chair; and (c) Defendant failed to warn Plaintiff not to sit on the chair.

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


WHEREFORE Plaintiff demands judgment against Defendant for compensatory damages and further demands a trial by jury of all issues so triable.   

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on this ____ day of FEBRUARY, 2006, a true and correct copy of the foregoing was mailed to: Magaly C. Lujardo, Esq., Lane, Reese, Aulick, Summers & Ennis, P.A., 2600 Douglas Road, Suite 300, Coral Gables, FL 33134.    
                                     

LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff(s)
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL  33009
Telephone:  (954) 458-8655
Facsimile: (954) 455-9649

By______________________________
ALAN D. SACKRIN    
Florida Bar No. 349070    

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This document is a sample lawsuit related to a specific set of facts and circumstances and should not be used or relied upon for any injury matter. We recommend and urge you to consult with an experienced injury lawyer for professional advice as each case is unique.

 

 

 


 
         
         
       

 

 

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