IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
Case No. XX
The Plaintiff, JENNIFER JAMES, sues the Defendant, TARGET CORPORATION., and alleges:
- This is an action for damages in excess of $XX, exclusive of interest, costs and attorney’s fees.
- On or about XX, 20__, the Defendant owned and/or operated a retail store (Target #XX) located at XXXX.
- At that time and place, Plaintiff went on to Defendant’s premises to shop when he slipped and fell on milk or some other foreign substance on the floor.
- The milk or other foreign substance on the floor constituted a dangerous condition which was either created by the Defendant, known by the Defendant, or should have been known by the Defendant, or resulted from the Defendant’s method of operation, and the Defendant should have corrected the condition or warned of its existence.
- As a result of the Defendant’s negligence, Plaintiff suffered permanent bodily injury and resulting pain and suffering, disability, 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 and/or aggravation of a pre-existing condition. 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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