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

CASE NO.: 00-xxxx (xx)

G.B.,
                            Plaintiff,
vs.

HISTORIC TOURS OF AMERICA, INC.
d/b/a OLD TOWN TROLLEY TOURS
                            Defendants.
_________________________________/

COMPLAINT

The Plaintiff, G.B., sues the Defendant, HISTORIC TOURS OF AMERICA, INC. d/b/a OLD TOWN TROLLEY TOURS and alleges:

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

2. Defendant is a Florida corporation that is engaged, at least in part, in the transportation of persons on trolleys for sight-seeing tours.

3. On or about [date], Plaintiff was traveling on one of Defendant’s trolley’s which was being operated by an employee of the Defendant.

4. Due to Plaintiff’s age and physical condition as well as due to the height of the step to get on the trolley, she needed assistance boarding the trolley and getting off the trolley.

5. Defendant knew or should have known that Plaintiff needed the assistance described in paragraph # 4, above.

6. When Plaintiff attempted to exit the trolley, she called for assistance; however, no assistance came and she fell as when exiting the trolley.

7. Defendant, through its employees, was negligent in its operation of the trolley causing Plaintiff to fall in that:

    a) there was an insufficient number of employees to assist passengers; and

    b) no assistance came to Plaintiff, although she requested it; and

    c) Defendant knew that Plaintiff needed assistance getting off of the vehicle but did not provide any such assistance; and

    d) the trolley did not come equipped with devices or other aides which would have enabled Plaintiff to safely exit the trolley.

8. 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, and expense of hospitalization, medical and nursing care and treatment. As the injuries are permanent, Plaintiff will continue to suffer losses in the future.

WHEREFORE, the Plaintiff, G.B., demand judgment for compensatory damages against the Defendant, HISTORIC TOURS OF AMERICA, INC. d/b/a OLD TOWN TROLLEY TOURS, and further demands a trial by jury of all issues so triable.

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

By______________________________
   ALAN D. SACKRIN 
   Florida Bar No. 349070

   /kb

The above pleading is a sample of Alan Sackrin's 30-plus years of injury litigation experience.  To learn more about Alan Sackrin, click on this link:  Florida Personal Injury Lawyer

                          Do You Have a Question?

Call us at 954-458-8655.  We promise to get back to you promptly.  Ask now.

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

 

 

Broward County Lawyers

(954) 458-8655