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Complaint - Walking in Parking Lot and Fall in Hole

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

CASE NO. xx-xxxx-xx

JOANNE D.,
Plaintiff,

vs.

SIGNATURE GRAND LTD.,
Defendant.
__________________________/

COMPLAINT

The Plaintiff, JOANNE D., sues the Defendant, SIGNATURE GRAND LTD., and alleges:

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

2.  On or about [date], the Defendant was the owner and in control of premises located at 6900 State Road 84 in Davie, Broward County, Florida, which premises were used as a hotel and convention center.

3.   On [date], Plaintiff went on to Defendant’s premises to attend a seminar.  

4.   As Plaintiff was walking in Defendant’s parking lot in a grassy area, she tripped and fell when she stepped into a hole which was difficult to detect.

5.   The condition which caused the Plaintiff to fall was a dangerous condition which was created by the Defendant, known to the Defendant, or should have been known to the Defendant in the exercise of reasonable care, and it should have been corrected or Plaintiff should have been warned of its existence.
 
6.  As a result of the negligence of the Defendant, Plaintiff suffered 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 permanent aggravation of a pre-existing condition.   As the injuries are permanent, Plaintiff will continue to suffer damages in the future.

WHEREFORE Plaintiff demands judgment for compensatory damages against the Defendant and further demands 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.

 

Quick Slip And Fall Facts:

Slip and falls are the second leading cause of injuries and deaths after car accidents. Every hour an older adult dies as a result of a fall. The most common injuries resulting from slip and falls include, herniated disc, head injury and/or a knee injury. Learn more from Alan Sackrin, an expert slip and fall lawyer.

 

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Since 1982, Alan Sackrin has represented clients throughout Florida in recovering monetary damages for slip & fall, trip & fall, and other premises liability injuries. Alan is a Board Certified Civil Trial Expert that strives to maximize the amount of compensation his clients' receive for their claim.  Alan brings a high-level of skill and knowledge to his slip and fall cases and he offers a free initial consultation.

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