IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: XX
AMUSEMENT PARK, LLC.,
The Plaintiff, ROBERT JONES, sues the Defendant, AMUSEMENT PARK, LLC., and alleges:
- This is an action for damages in excess of $XX, exclusive of interest, costs and attorney=s fees.
- Defendant is a limited liability foreign corporation doing business in Broward County, Florida.
- On or about XX, 20__, Defendant was the owner and operator of an amusement park in XX.
- As part of the amusement park, Defendant owned and operated a go-cart track.
- On XX, 20__, Plaintiff was lawfully on Defendant’s premises as a customer operating a go-cart on the go-cart track.
- At that time and place, Plaintiff was injured when debris which was on the go-cart path “kicked-up” from another go-cart on the path, striking Plaintiff in the knee.
- The incident and resulting injuries to Plaintiff were caused by the negligence of the Defendant in that:
(a) The go-cart course was in an unreasonably dangerous condition given the debris, including rocks and dirt, that was on the course; and
(b) The operator of the go-cart which went over the debris causing Plaintiff’s injury was driven by an on-duty employee of the Defendant who drove the go-cart at on excessive speed and careless manner causing the debris to strike Plaintiff.
- As a result of the negligence of the Defendant, Plaintiff suffered permanent bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, and expense of hospitalization, medical and nursing care and treatment. As the injuries are permanent, Plaintiff will continue to suffer damages in the future.
WHEREFORE, the Plaintiff, ROBERT JONES, demand judgment for compensatory damages against the Defendant, AMUSEMENT PARK, LLC., 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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