PA 106 Unit 4 Assignment part 2

IN THE CIRCUIT COURT FOR PORTAGE COUNTY, INDIANA.

TOM SMITH,

Plaintiff.

vs.JURY DEMAND

LA GRANDE FROMAGE LLCFile No. 1234

LA FROMAGE.,

Defendant.

COMPLAINT

NEGLIGENCE

Now comes Plaintiff, Tom Smith by his attorneys Wagner and Evans LLP complaining of the Defendant, La Grande Fromage LLC here and after refferred to as Defendant states as follows…

WHEREFOR, the Plaintiff, Tom Smith demands judgement against the Defendant for the sum of one hundred thousand dollars ($100,000.00) plus cost of court and demands a jury to try this cause, Plaintiff also requests any and all other and future relief to which it might appear the Plaintiff is entitled.

  1. On and prior to the date of the incident Plaintiff, Tom Smith was a resident in the city of Portage, county of Porter, state of Indiana.
  2. At all times material to this incident the Defendant an Indiana limited liability company was doing business in the state of Indiana.
  3. Then on July 1st, 2015, the Defendant owned and was doing business as La Grande Fromage at 444 Ridge Rd. Portage, Indiana 46368.
  4. That on July 1st, 2015 the Plaintiff, Tom Smith was a patron and/or invitee lawfully on the premises of La Grande Fromage.
  5. The Defendant owes a duty to exercise reasonable care for Plaintiff’s safety.
  6. That on July 1st, 2015 the Plaintiff, Tom Smith was eating dinner with his wife at the Defendants property. Prior to dinner being served the Plaintiff got up from his seat to use the restroom. On the way to the restroom the Plaintiff, Tom Smith slipped and fell on a slippery substance on the floor in the front of the men’s restroom.
  7. That on July 1st, 2015 Defendant knew or in the exercise of reasonable care should have known of a dangerous condition or Defendant created a dangerous condition through the acts of its employees in a negligent manner.
  8. That Defendant should have corrected the condition or warned Plaintiff of its existence.
  9. As a result of the Defendants negligence, the Plaintiff, Tom smith slipped and fell.
  10. As a result of the negligence of the Defendant, Plaintiff, Tom Smith 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 including loss of ability to earn money.
  11. Plaintiff will continue to suffer losses in the future from the aforementioned permanent injuries.

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Plagiarism Free!

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