|Chair Accident Complaint-Manufacturer Negligence|
IN THE CIRCUIT COURT OF THE
THE HON COMPANY, a foreign
C O M P L A I N T
The Plaintiff, LB, sues the Defendant, THE HON COMPANY, a foreign corporation, and alleges:
2. The Defendant, THE HON COMPANY, is an Iowa corporation which at all times material hereto conducted business in Florida by delivering office furniture in Florida. Personal jurisdiction is predicated upon §48.193, Fla. Stat., in that the Defendant has committed a tort in the State of Florida.
3. While at work in Broward County, Florida, on March 15, 2000, the Plaintiff sat on a chair manufactured and/or distributed by the Defendant, THE HON COMPANY, when the chair (Model No. 6602AB, Serial No. 80F00) suddenly and unexpectedly broke, causing Plaintiff to fall to the floor.
4. At the time the subject chair left the possession of the Defendant, it was in a condition unreasonably dangerous to the user, and the chair was expected to and did reach the user (Plaintiff) without substantial change affecting that condition in that it broke during normal use.
5. In addition thereto or in the alternative, the chair was defective in its design when it left the possession of the Defendant as the chair failed to perform as safely as an ordinary consumer would expect when used as intended or used in a manner reasonably foreseeable by the manufacturer or the risk of danger in the design outweighed its benefits.
6. As the result of the defective manufacture and/or defective design of the subject chair, Plaintiff suffered permanent bodily injury and resulting pain and suffering, disability disfigurement, mental anguish, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of the ability to earn money, and/or permanent aggravation of a previously existing condition. As the injuries are permanent, Plaintiff will continue to suffer damages in the future.
LAW OFFICE OF ALAN D. SACKRIN
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