Fill and Sign the Fall Stairs Form

IN THE COUNTY COURT OF THE ____________ JUDICIAL DISTRICT OF _____________ COUNTY, ____________ ___________________________________ PLAINTIFF VS. CIVIL ACTION NO. __________________ ____________________________________ DEFENDANT COMPLAINT ( Jury Trial Requested) COMES NOW the Plaintiff, _____________________, hereinafter referred to as "_________," and files this, his Complaint, against the Defendant, _______________________, hereinafter referred to as "_________," and in support thereof, would show unto the Court the following matters and facts, to-wit: 1. The Plaintiff _______________ is an adult resident citizen of _______________ County, ____________ 2. The Defendant, is a legal entity organized and existing under the laws of the State of ____________ and may be served with process by serving ____________ Executive Director,____________, at ______________, __________,____________, or by mail at Post Office Box _______, ______________. 3. At approximately ________ p.m. on ________, _______ ___, 20___, while going to retrieve his luggage from a _____________flight from _______, ______, _______________ slipped on one of the flights of stairs leading to the first floor of the Airport operated by _______________, ___________________( A _______ @ ). 1 4. At about ___ A.M. the next day, _______________ awoke with excruciating pain in his neck. _______________ went to see ________________-, as soon as he opened his clinic at about ____________for diagnosis and treatment. In addition to injuring his neck, _______________ injured his lower back and developed weakness in his right hand that ______________said was related to his fall. _______________ also has experienced pain shooting from his right shoulder to his right hand. 5. That at the time of his fall, the stairs were extremely wet and slippery and there was no sign that warned of the wet condition of the stairs. It had been raining in ________ and people from outside had come inside and water had dripped from their shoes, coats and/or umbrellas onto the stairs. It was not raining at the time _______________ fell. 6. _______________, as the operator of a public airport, owed to _______________ a duty to exercise the highest degree of care regarding his safety while in the ________ and using the stairs to the frst foor of the ___________, and at all other times during which _______________ was lawfully using _________ facilities. 7. Defendant, in breach of the duty described above, negligently failed to: A. Properly maintain the steps on which Plaintif fell; B. Remove water from the step on which Plaintif fell when Defendant knew, or in the exercise of reasonable care should have known, that the stairs were wet and slippery; C. Warn Plaintif of the dangerous and hazardous condition of the steps on which Plaintif fell, which condition Defendant knew or should have known 2 about; and D. Otherwise exercise due care with respect to the matters alleged in this Complaint. 8. As a direct and proximate result of the negligence of Defendant as described above, Plaintif sufered bodily injury and resulting pain and sufering, disability; mental anguish; loss of capacity for the enjoyment of life; medical expenses, loss of earnings; temporary loss of ability to earn money; and aggravation of a known or unknown previously condition. WHEREFORE, PREMISES CONSIDERED , Plaintiff does hereby demand judgment against _______________ in the amount of $__________ regarding actual damages and $___________ in punitive damages, plus reasonable attorneys = fees and court costs. Respectfully submitted, __________________________ ___ No. ____________ __________________________ Attorney at law __________________________ __________________________ Telephone - ________________ Telefax - ___________________ 3