IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. XX
C O M P L A I N T
The Plaintiff, MARY GARCIA, sues the Defendant, SMITH INC., and alleges:
- This is an action for damages that exceed $XX, exclusive of interest, costs and attorney’s fees.
- On or about XX, 20__, Defendant, SMITH INC., owned and operated a shopping center as the XX.
- As part of its ownership of the shopping center, Defendant owned, and Defendant or its agent maintained, one or more ladders which were affixed to the shopping center.
- On XX, 20__, Plaintiff was working on the air conditioning or refrigeration system of one of the tenants of SMITH INC.
- At that time, Plaintiff began climbing one of the ladders affixed to the building in order to gain access to the roof when he slipped and fell as a result of grease or some other slippery substance on one of the rungs of the ladder.
- The grease or other slippery substance was placed on the rung of the ladder by an employee or an agent of the Defendant and it constituted an unreasonable risk of harm to those who used the ladder.
- As a result of the negligence of Defendant’s employee or agent, Plaintiff, MARY GARCIA, suffered permanent bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, physical impairment, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of the ability to earn money, and/or aggravation of a previously existing condition. As the injuries are permanent, Plaintiff will 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
Attorneys for Plaintiff
2100 East Hallandale Beach Blvd.
Hallandale Beach, FL 33009
ALAN D. SACKRIN
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