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COMPLAINT – CVS – BATTERY IN PARKING LOT

COMPLAINT

IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NUMBER: XX

MELISSA THOMPSON,

 

Plaintiffs,

vs.

 

CVS PHARMACY, INC.,

 

Defendant.

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COMPLAINT

The Plaintiff, MELISSA THOMPSON, sues the Defendant, CVS PHARMACY, INC., and alleges:

  1. This is an action for damages in excess of $XX, exclusive of interest, costs, and attorney=s fees.
  2. The Defendant is a foreign corporation, which is subject to the jurisdiction of the Florida court as it conducts substantial and continuous business activities in Florida and has a registered agent in this State.
  3. On or about XX, 20__, Plaintiff was in the passenger seat of a vehicle parked in a CVS Pharmacy parking lot in Miami-Dade County, FL.
  4. While seated in the vehicle, the Plaintiff was attacked by gunpoint and pistol whipped on her forehead.
  5. The driver of the vehicle ran inside CVS to get help, however, the store manager took no immediate action.
  6. As a result of the negligence of Defendant’s employee for which Defendant is liable, 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.

LAW OFFICE OF ALAN D. SACKRIN

Attorney for Plaintiff(s)

2100 East Hallandale Beach Blvd.

Suite 200

Hallandale Beach, FL  33009

 

By______________________________

ALAN D. SACKRIN

 

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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.

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