IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NUMBER:
W. F.,
Plaintiff,
vs.
AJE GOURMET PRODUCTS LLC.
Defendant.
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COMPLAINT
The Plaintiff, W. F., sues the Defendant, AJE GOURMET PRODUCTS LLC., and allege:
1. This is an action for damages in excess of $15,000.00, exclusive of interest, costs, and attorney fees.
2. On March 21, 2007, Plaintiff was an employee of W. F., Inc. and Plaintiff was delivering produce products to Defendant at Defendant’s facility in Pompano Beach, Florida.
3. While unloading produce, Defendant was assisted by one of Defendant’s employees.
4. Defendant’s employee advised Plaintiff to stand on a fork-lift during the process of removing the produce from Defendant’s truck.
5. Defendant’s employee assured Plaintiff that he would not abruptly move the fork-lift or make any other motion which would cause Plaintiff to fall.
6. Defendant’s employee did in fact abruptly move the fork-lift jack or made some other motion which caused Plaintiff to fall and seriously injure himself.
7. As a result of the negligence of Defendant’s employee while in the course and scope of his employment with the Defendant, Plaintiff suffered permanent bodily injury, resulting pain and suffering, disability, disfigurement, inconvenience, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care treatment and treatment, loss of earnings, loss of ability to earn money in the future and/or permanent aggravation of a previously existing condition. As the injuries are permanent, Plaintiff will suffer damages in the future.
WHEREFORE Plaintiff demands judgment against Defendant for compensatory damages and further demands a trial by jury of all issues so triable.
ALAN D. SACKRIN
Attorney for Plaintiff(s)
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
By______________________________
ALAN D. SACKRIN
Florida Bar No. 349070
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