1. Plaintiff is a citizen of North Carolina, residing at 123 Shirtsleeve Drive, Durham, North Carolina, 27517. The action occurred in the state of North Carolina, county of Durham.
2. Defendant is incorporated to do business in the state of North Carolina, with the principal location of business being 456 Food Shop Road, Durham, North Carolina, 27517, and the defendant’s registered agent is Marco Lario, who can be served at that address.
3. On April, 9, 2017 the plaintiff was shopping for food at the defendant’s store when the automated conveyer belt caught her sleeve causing her to suffer the injuries and damages listed …show more content…
Plaintiff’s injuries included a dislocated shoulder, loss of consciousness, and a laceration on her head.
5. Due to the injuries sustained by the plaintiff at the defendant’s store the plaintiff has been unable to work and has incurred expensive medical bills ($25,000).
6. Plaintiff has suffered prolonged damage due to the unlikelihood of her complete recovery and inability to return to work coupled with emotional damages from the action.
WHEREFORE, the plaintiff prays for judgment against the defendant in an amount to be proven at trial, including medical bills, lost wages, costs of damaged clothing, pain and suffering, costs expended in filing this suit, interest from the date of the commencement of this action, expert witness fees, attorney’s fees, and for any other and further relief that this Court may seem proper and just.
THE PLAINTIFF DEMANDS THAT THIS ACTION BE TRIED TO A JURY.
The defendant, Foods Deluxe, by and through its counsel, Robert Smith, for its Answer states and alleges the following:
1. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegation contained in paragraph 1 of the Complaint, and therefore, denies this