Miami Injury Attorney Justin Ziegler filed a lawsuit and discovery in Miami-Dade County Florida which alleges that a resident of Miami, Florida was injured when eating at a Denny's restaurant in North Miami Beach, Florida when his booth seat came loose sending him to the floor resulting in serious injury. The lawsuit seeks medical bills, lost wages, and pain and suffering. The Defendant has been served with a summons. Mr. Baptiste has requested a jury trial.
Miami, Florida (PRWEB) March 5, 2008 -- On November 28, 2007, in Miami Dade County Florida, Miami Personal Injury Lawyer Justin Ziegler, on behalf of his client, Winslight Baptiste filed a lawsuit against KS & P Restaurants, LLC. The complaint alleges that Mr. Baptiste's damages are in excess of Fifteen Thousand Dollars ($15,000.00) exclusive of attorney's fees and costs. The Complaint alleges that, Winslight Baptiste, was a Miami-Dade resident, and that Defendant, KS & P Restaurants, LLC is a corporation in Florida and at the time of the accident owned and operated a restaurant located in Miami-Dade County, Florida.
In the complaint, Mr. Ziegler states "Mr. Baptiste was an invitee at Denny's located at 3323 NE 163 street, North Miami, Florida for the purposes of dining there. He was sitting at a booth when he was getting up to leave, the booth flipped up and caused him to fall due to the negligent acts and omissions of the Defendant, KS & P Restaurants, LLC, in that it negligently created a dangerous or negligent condition, to wit: a) by failing to provide a safer seating environment for a business patron or invitee to sit upon The Defendant b) In failing to keep its premises in a safe and proper condition for the use of its invitees or patrons. c) In failing to warn the plaintiff, Winslight Baptiste, of the dangerous condition of said failure to keep premises including, but not limited to the seating environment, in a safer condition, which caused the slip and fall.
In the complaint, Mr. Ziegler alleges that the Defendant, KS & P Restaurants so recklessly or negligently maintained, operated or controlled their premises as to cause the Plaintiff, Winslight Baptiste, to be injured when the Defendant, KS & P Restaurants, allegedly caused the premises to be unsafe, and knew, or in the exercise of reasonable care should have known that the said area was not in a reasonably safe condition commensurate with the circumstances of use by customers.
The complaint states that the Defendant employed incompetent, unskilled, or careless employees and/or failed to exercise proper supervision of its employees in maintaining the area in a safe condition, thereby causing serious injuries to the Plaintiff, Winslight Baptiste.
Mr. Ziegler states in the complaint that as a direct and proximate result of the alleged negligence by Defendant, KS & P Restaurant, LLC, the Plaintiff, Winslight Baptiste, has suffered bodily injury, and resulting in pain and suffering, disability, disfigurement, mental anguish and pain, loss of earnings, loss of ability to earn money and has incurred substantial medical expenses for treatment and care, past, present and future. The Complaint states that Mr. Baptiste's losses are continuing in nature and he will continue to suffer them in the future.
The Complaint which Mr. Ziegler filed demands judgment for damages against the Defendant, KS & P Restaurant, and LLC in an amount exceeding Fifteen Thousand Dollars ($15,000.00) together with the costs of the lawsuit and further demands trial by jury. Miami Personal Injury Lawyer Justin Ziegler filed a request for production along with interrogatories in with the court.
Mr. Ziegler's request for production asks the Defendant to produce the following: 1: seeks any statements of the Plaintiff 2: any photographs, pictures, films, movies, video-tapes or other pictures of the plaintiffs. 3: The request to produce also asks for any photographs, pictures, films, movies, video-tapes or other pictures of the accident scene and subject restaurant. 4: Any reports which describe medical treatment offered or received by the Plaintiff. 5. Any and all written or recorded statements made by the Plaintiff in reference to the subject accident or in reference to the injuries received as a result of the subject accident.
Plaintiff, Winslight Baptiste's, request for production also asks for any and all insurance policies that may provide coverage to you for the facts and circumstances alleged in the complaint. On December 6, 2007 the registered agent was served with the complaint.
Miami Dade County Case # 07-41496
Justin Ziegler, P.L. offers a free consultation to injured accident victims throughout Florida. There are no fees or costs unless his law firm recovers money for you. Mr. Ziegler's website is www.justinziegler.net. He can be reached toll-free at (800) 955-5085.
Source: PRWeb: Legal / Law
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