Complaint in a Trip-And-Fall Case
Content
Form 3:01
Complaint in a Tr Trip-and-Fall ip-and-Fall Case [Illinois [ Illinois Rules]
[Caption] COMPLAIT
COMES NOW the Plaintiff, , by and through her attorneys, , and for her Complaint against the Defendant, , states as follos! "# $h $hat at on or abou aboutt De%e De%emb mber er &, '(() '((),, the the Defe Defend ndan antt one oned, d, mana manage ged, d, oper operat ated ed,, maintained, and %ontrolled, both dire%tly and indire%tly, indi*idually and through its agents, agents, ser*ants, ser*ants, and employees, employees, a %ertain %ertain shopping shopping %enter +non as and lo%ated at , llinois# '# $hat on and before before that date, date, the Defendan Defendantt in*ited in*ited the general general publi%, publi%, in%ludi in%luding ng the Plaintiff, to enter said shopping %enter for the purpose of the operation of the shopping %enter# &# $hat it then then and there there be%ame and and as the duty duty of the Defenda Defendant, nt, indi*idual indi*idually ly and by and through its agents, ser*ants and employees, to +eep the premises in a reasonably safe %ondition for the Plaintiff and other persons lafully in and about the shopping %enter, and further, not to %reate or allo any dangerous %onditions to e-ist on or about the premises# )# $hat at the abo*e abo*e date date and pla%e, pla%e, the Plaint Plaintif iff, f, , as laful lafully ly on the sub sub.e% .e%tt premises, al+ing in the shopping %enter# /# $hat, $hat, disreg disregard arding ing its stated stated duty, duty, Defendant Defendant,, by its agents, agents, employee employeess and ser*ants ser*ants,, %ommitted the folloing a%ts and omissions! a# failed failed to pro*ide pro*ide a good, safe safe and proper proper pla%e pla%e for the the Plaintiff Plaintiff to to be, use, o%%upy o%%upy and al+ on hile on the sub.e%t premises0 b# alloed and permitted the sub.e%t premises to be%ome and remain in a dangerous %ondition0 %# failed failed to inspe% inspe%tt the premise premisess to be %ertain %ertain that they ere ere in good, safe safe and proper proper %ondition0 d# fail failed ed to arn arn the the Plai Plaint ntif ifff and and othe others rs of the the unsa unsafe fe,, defe defe%t %ti* i*ee and and dange dangero rous us %ondition of the sub.e%t premises0 e# failed failed to safeguard safeguard its its %ustomers %ustomers by maintai maintaining ning e1uipment e1uipment in an unsafe unsafe lo%atio lo%ation0 n0 f# failed failed to to arn %ust %ustome omers rs of obst obsta%l a%les es in al+ al+ay ays0 s0 g# fail failed ed to arn arn %ust %ustom omers ers of prot protru rudi ding ng part partss on e1uip e1uipme ment nt lo%at lo%ated ed in %ust %ustom omer er al+ays# 2# $h $hat at as a dire dire%t %t and pro-i pro-ima mate te resul resultt of one or more more of these these neglig negligen entt a%ts a%ts and3or and3or omissions of the Defendant, indi*idually and by and through its agents, ser*ants, and employees, the Plaintiff as %aused to fall# 4# $h $hat at as a dire dire%t %t and propro-im imat atee resu result lt of this this fall, fall, the the Plai Plaint ntif ifff has suffe suffere red d se*e se*ere re,, e-tens e-tensi*e i*e and perman permanent ent in.uri in.uries, es, both both e-terna e-ternally lly and intern internall ally y, and as and ill ill %ontinue to be hindered in attending to usual duties and affairs, and has lost and ill in the future lose the *alue of this time# 5s a result of those in.uries, the Plaintiff has be%ome liable for large sums of medi%al bills and ill e-pend and3or ill be%ome liable for additional medi%al bills in the future# 6# $hat as a dire%t dire%t and pro-imate pro-imate result result of this fall, fall, the Plainti Plaintiff ff has suffer suffered ed loss of in%ome# in%ome#
W7E8E9O8E! the Plaintiff, , prays that this %ourt enter its .udgment against the Defendant, , in a sum in e-%ess of :/(,((( plus Court %osts# 8espe%tfully submitted, [Mo*ing Party] ;y One of its attorneys [Certifi%ate of Ser*i%e]
Complaint in a Tr Trip-and-Fall ip-and-Fall Case [Illinois [ Illinois Rules]
[Caption] COMPLAIT
COMES NOW the Plaintiff, , by and through her attorneys, , and for her Complaint against the Defendant, , states as follos! "# $h $hat at on or abou aboutt De%e De%emb mber er &, '(() '((),, the the Defe Defend ndan antt one oned, d, mana manage ged, d, oper operat ated ed,, maintained, and %ontrolled, both dire%tly and indire%tly, indi*idually and through its agents, agents, ser*ants, ser*ants, and employees, employees, a %ertain %ertain shopping shopping %enter +non as and lo%ated at , llinois# '# $hat on and before before that date, date, the Defendan Defendantt in*ited in*ited the general general publi%, publi%, in%ludi in%luding ng the Plaintiff, to enter said shopping %enter for the purpose of the operation of the shopping %enter# &# $hat it then then and there there be%ame and and as the duty duty of the Defenda Defendant, nt, indi*idual indi*idually ly and by and through its agents, ser*ants and employees, to +eep the premises in a reasonably safe %ondition for the Plaintiff and other persons lafully in and about the shopping %enter, and further, not to %reate or allo any dangerous %onditions to e-ist on or about the premises# )# $hat at the abo*e abo*e date date and pla%e, pla%e, the Plaint Plaintif iff, f, , as laful lafully ly on the sub sub.e% .e%tt premises, al+ing in the shopping %enter# /# $hat, $hat, disreg disregard arding ing its stated stated duty, duty, Defendant Defendant,, by its agents, agents, employee employeess and ser*ants ser*ants,, %ommitted the folloing a%ts and omissions! a# failed failed to pro*ide pro*ide a good, safe safe and proper proper pla%e pla%e for the the Plaintiff Plaintiff to to be, use, o%%upy o%%upy and al+ on hile on the sub.e%t premises0 b# alloed and permitted the sub.e%t premises to be%ome and remain in a dangerous %ondition0 %# failed failed to inspe% inspe%tt the premise premisess to be %ertain %ertain that they ere ere in good, safe safe and proper proper %ondition0 d# fail failed ed to arn arn the the Plai Plaint ntif ifff and and othe others rs of the the unsa unsafe fe,, defe defe%t %ti* i*ee and and dange dangero rous us %ondition of the sub.e%t premises0 e# failed failed to safeguard safeguard its its %ustomers %ustomers by maintai maintaining ning e1uipment e1uipment in an unsafe unsafe lo%atio lo%ation0 n0 f# failed failed to to arn %ust %ustome omers rs of obst obsta%l a%les es in al+ al+ay ays0 s0 g# fail failed ed to arn arn %ust %ustom omers ers of prot protru rudi ding ng part partss on e1uip e1uipme ment nt lo%at lo%ated ed in %ust %ustom omer er al+ays# 2# $h $hat at as a dire dire%t %t and pro-i pro-ima mate te resul resultt of one or more more of these these neglig negligen entt a%ts a%ts and3or and3or omissions of the Defendant, indi*idually and by and through its agents, ser*ants, and employees, the Plaintiff as %aused to fall# 4# $h $hat at as a dire dire%t %t and propro-im imat atee resu result lt of this this fall, fall, the the Plai Plaint ntif ifff has suffe suffere red d se*e se*ere re,, e-tens e-tensi*e i*e and perman permanent ent in.uri in.uries, es, both both e-terna e-ternally lly and intern internall ally y, and as and ill ill %ontinue to be hindered in attending to usual duties and affairs, and has lost and ill in the future lose the *alue of this time# 5s a result of those in.uries, the Plaintiff has be%ome liable for large sums of medi%al bills and ill e-pend and3or ill be%ome liable for additional medi%al bills in the future# 6# $hat as a dire%t dire%t and pro-imate pro-imate result result of this fall, fall, the Plainti Plaintiff ff has suffer suffered ed loss of in%ome# in%ome#
W7E8E9O8E! the Plaintiff, , prays that this %ourt enter its .udgment against the Defendant, , in a sum in e-%ess of :/(,((( plus Court %osts# 8espe%tfully submitted, [Mo*ing Party] ;y One of its attorneys [Certifi%ate of Ser*i%e]
