IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. XXXX
SMITH ROOFING SERVICES,
The Plaintiff, RICHARD ROGERS, sues the Defendant, SMITH ROOFING SERVICES, and alleges:
- This is an action for damages in excess of $XXXX, exclusive of interest, costs and attorney’s fees.
- On or about XX, 20__, Plaintiff, RICHARD ROGERS, was at the XXXX located in XXXX.
- 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.
- Defendant’s employees were also negligent in failing to alert Plaintiff that tar-pouring operations were under way.
- 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.
Hallandale Beach, FL 33009
ALAN D. SACKRIN
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