IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO: XXXX
The Plaintiff, JOHN SMITH, sues the Defendant, VACATION CRUISES and alleges:
- This is an action for damages that exceeds $XXXX, exclusive of interest, costs, and attorney=s fees.
NEGLIGENCE AGAINST DEFENDANT
- All conditions precedent to the maintenance this certain have been satisfied.
- On or about XXXXX, Plaintiff was a passenger on board the vessel XXXX which is owned and operated by the Defendant, VACATION CRUISES.
- While in XX on XXXXX, the XXX was anchored in the open sea which required the use of tenders to transport passengers to and from the shore.
- On that date, Plaintiff boarded a tender to take him from the land to the ship.
- The tender was operated by employees or agents of the Defendant and was under the exclusive control of the Defendant.
- The Defendant was negligent, through its employees, in its operation of the tender on XXX resulting in injuries to Plaintiff sustained while on the tender in that:
(a) The strong winds and high waves should have caused suspension of the tender service until it was substantially safer to operate the tender; and
(b) Defendant’s employees or agents were negligent in that they failed to control the tender in the open sea and while attempting to dock the tender adjacent to the XXX; and
- As a result of Defendant=s negligence, Plaintiff was injured in and about his body and extremities, suffered pain therefrom, incurred medical expense in the treatment of his injuries and suffered physical handicap and his working ability was impaired. As the injuries are permanent or continuing in nature, Plaintiff will suffer damages, losses and impairment in the future.
WHEREFORE Plaintiff demands judgment against Defendant for compensatory damages 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
ALAN D. SACKRIN
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