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Complaint – Walmart Substance on Floor in Frozen Food Dept.

IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA

CASE NO.: XXXXXXX

B.O.G.
    Plaintiff,

  vs.

WAL-MART STORES, INC.,
  Defendant.
_________________________________/

COMPLAINT

The Plaintiff, XXXXXXX, sues the Defendant, WAL-MART STORES, INC., and alleges:

1. This is an action for damages in excess of $15,000.00, exclusive of interest, costs and attorney’s fees.

2. Defendant, WAL-MART STORES, INC., is a foreign corporation which at all material times conducted business in the State of Florida and is subject to jurisdiction in Florida as it has committed a tort in Florida.

3. On or about June XX, 20XX, Defendant, WAL-MART STORES, INC., was the owner and operator of a Wal-Mart Super Center, Store #5325, in Broward County Florida.

4. On that date, Plaintiff went onto Defendant’s premises to shop when she was caused to slip and fall as a result of water or some other transitory substance on the floor in the frozen food department.

5. Defendant knew, or, in the exercise of reasonable care should have known, of the condition, or Defendant created the condition either through the acts of its employees, in its negligent maintenance of equipment, or in its negligent method of operation, and Defendant should have corrected the condition or warned Plaintiff of its existence.  Additionally, Defendant should have had non-slip surface which will would have prevented the fall which resulted from a foreseeable condition.

6. 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, expense of hospitalization, medical and nursing care, treatment, and loss of earnings of loss of ability to earn money. As the injuries are permanent, Plaintiff will continue to suffer losses in the future.

WHEREFORE, the Plaintiff, XXXXXXX, demand judgment for compensatory damages against the Defendant, WAL-MART STORES, INC., and further demands a trial by jury of all issues so triable.

ALAN D. SACKRIN, Esq.
Slip and Fall Attorney
Attorney for Plaintiff
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649
www.Hallandalelaw.com

By: _________________________
ALAN D. SACKRIN
Florida Bar No. 349070

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