Slip & Fall Pleading

IN THE CIRCUIT COURT FOR PRINCE GEORGE’S COUNTY, MARYLAND

JANE DOE *
5555 Main Street
Annapolis, MD 21401 *
Plaintiff *
v. *
Case No.:
SAFESTORE *
11 Kenilworth Avenue
Greenbelt, MD 20770 *
SERVE ON: *
Resident Agent
7 Greene Street *
Baltimore, MD 21202 *
Defendant

COMPLAINT

COMES NOW the Plaintiff, Jane Doe, by and through her attorneys, FORAN, & FORAN, P.A., and sues the Defendant, Safestore, and for reasons therefore, states as follows:

1. That the Plaintiff, Jane Doe, is an adult resident of Anne Arundel County, Maryland.
2. That the Defendant, Safestore, is a Delaware corporation licensed to do business throughout the state of Maryland, including Prince George’s County, Maryland.
3. That on or about January 2, 2008, while the Plaintiff, Jane Doe, was a business invitee, shopping at one of the Defendant, Safestore’s grocery stores located at 11 Kenilworth Avenue, Greenbelt, Prince George’s County, Maryland, 20770, the Plaintiff, Jane Doe, slipped and fell on a large area of a slippery substance that had accumulated on the floor.
4. That the Defendant, Safestore, owed a duty to the Plaintiff, Jane Doe, to maintain the floor in its store in a safe and clean manner. Said Defendant had knowledge, actual and/or constructive, of said dangerous conditions and failed to remedy same, including but not limited to failing to properly clean up the large area of said slippery substance expeditiously, and/or failing to warn Plaintiff of the dangerous condition of the premises, failing to properly inspect the premises, thereby causing the ensuing incident.
5. That at all times in question, the Plaintiff, Jane Doe, acted in a careful and prudent manner, without any negligence contributing to the resultant accident.
COUNT I
(Negligence)
6. That the Plaintiff, Jane Doe, adopts and incorporates all of the facts and allegations set forth above as if fully set forth herein.
7. That as a direct and proximate result of the aforesaid accident, which was caused by the negligence of the Defendant, Safestore, the Plaintiff, Jane Doe, who was at all times exercising due care, suffered severe pain and permanent injuries to her body, including her left ankle and left leg, as well as severe and protracted shock to her nervous system, all of which have caused and will continue to cause her great pain and mental anguish.
8. That as a further direct and proximate result of the aforesaid negligence of the Defendant, Safestore, the Plaintiff, Jane Doe, has been forced to expend and will continue to expend large sums of money for hospitalization, x-rays, doctors, nurses, medical treatment, and medicine for treatment of the aforesaid injuries to herself.
9. WHEREFORE, the Plaintiff, Jane Doe, demands judgment against the Defendant, Safestore, in the amount of Three Hundred Thousand Dollars ($300,000.00) for damages, together with the costs of this action and such other relief as is deemed just and proper.

Respectfully submitted,
FORAN & FORAN, P.A.

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Ryan J. Foran
Attorneys for Plaintiff
6301 Ivy Lane, Suite 600
Greenbelt, MD 20770
(301) 441-2022

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