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COMPLAINT- ROOFER – HOT TAR FELL ON VICTIM

COMPLAINT

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

CASE NO. XXXX

RICHARD ROGERS,

 

Plaintiff,

vs.

 

SMITH ROOFING SERVICES,

 

Defendant.

__________________________/

 

COMPLAINT

 

The Plaintiff, RICHARD ROGERS, sues the Defendant, SMITH ROOFING SERVICES, and alleges:

  1. This is an action for damages in excess of $XXXX, exclusive of interest, costs and attorney’s fees.
  2. On or about XX, 20__, Plaintiff, RICHARD ROGERS, was at the XXXX located in XXXX.
  3. While on the roof of the premises, employees of the Defendant, while acting in the course and scope of their employment, negligently poured hot tar, causing it to land on Plaintiff who was standing below.
  4. Defendant’s employees were also negligent in failing to alert Plaintiff that tar-pouring operations were under way.
  5. As a result of the negligence of the Defendant, Plaintiff suffered permanent bodily injury and resulting pain and suffering, disability, scarring and 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. 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

Attorney for Plaintiff

2100 East Hallandale Beach Blvd.

Suite 200

Hallandale Beach, FL 33009

 

By________________________________

ALAN D. SACKRIN

 

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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. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.

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