Filing # 192251051 E-Filed 02/19/2024 03:30:53 PM

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT

IN AND FOR ORANGE COUNTY, FLORIDA

CASE NUMBER:

TERRANCE HARRISON
Plaintiff,

VS.

EAGLE COPIER SOLUTIONS,

CORPORATION
Defendant(s).
/

COMPLAINT

COMES NOW, Plaintiff, TERRANCE HARRISON, sues Defendant, EAGLE COPIER

SOLUTIONS CORPORATION and alleges as follows:

PARTIES, JURISDICTION AND VENUE

1. This is a civil action for damages that exceeds $30,000.00, exclusive of costs and

attorney fees.

2. Upon information and belief, at all times material hereto, Defendant, EAGLE

COPIER SOLUTIONS CORPORATION (Defendanf), was a Florida corporation located in

Orlando, Orange County.

3. At all times hereto, Defendant was insured by a surplus line insurance carrier and

had coverage limits of $1,000,000 each occurrence; $2,000,000 general aggregate; and $5,000

medical payments.

4. At all times material hereto, Plaintiff, TERRANCE HARRISON ("Plaintiff) was

a resident of Orlando, Orange County, Florida.

5. The incident giving rise to this cause of action occurred on or about February 17,

2023, 8750 Exchange Dr STE 2, Orlando, FL 32809.

 6. Venue is proper in this county, inter alia, because the incident occurred in Orange

county.

COUNT I -NEGLIGENCE

7. Plaintiff hereby incorporates all factual allegations contained in paragraphs 1

through 6 above and further states as follows:

8. At all times material hereto, Plaintiff was entitled to be on the premises of the

Defendant while he carried out his job duties by delivering packages.

9. At said time, Plaintiff, who works as a delivery driver, was delivering a package to

the Defendant when a large dog, apparently belonging to Defendant came out of the building and

bit Plaintiff on his leg. The dog bite punctured Plaintiff s right lower shin causing him severe pain

and injury.

10. According to Fla. Stat. § 767.04, the owner of any dog that bites any person while

such person is on or in a public place, or lawfully on or in a private place, including the property

of the owner of the dog, is liable for damages suffered by persons bitten, regardless of the former

viciousness of the dog or the ownersknowledge of such viciousness.

11. Plaintiff was lawfully at the office of the Defendant in his capacity as a delivery

driver delivering a package to the business.

12. The Defendant had a duty to have his dog under control at all times.

13. The Defendant breached this duty when he allowed his dog to escape from inside

the building and attack Plaintiff.

14. There were no signs warning guests that a dog was present on the premises, and

Plaintiff had no way of anticipating that Defendant had a dog present.

15. As a direct and proximate result of the above-described accident, the Plaintiff
suffered bodily injury, mental anguish, loss of capacity for the enjoyment of life and expenses for

medical treatment. These losses are either permanent or continuing in nature, and the Plaintiff will

continue to suffer in the future.

WHEREFORE, the Plaintiff, TERRANCE HARRISON, demands judgment against the

Defendant, EAGLE COPIER SOLUTIONS CORPORATION, in excess of Thirty Thousand and

00/100 ($30,000.00), exclusive of costs and interest and requests a jury trial, and grant any other

relief the Court deems necessary.

By:/s/ Desiree Sanchez

Desiree Sanchez
State Bar No. 10082
Ronda Robinson
State Bar No. 1045409
SANCHEZ LAW GROUP, P.A.
605 E. Robinson Street, Suite 650
Orlando, FL 32801
Tel: (407) 500-4444
Fax: (407) 236-0444
E-Mail 1: desiree@sanchezlaw.com
E-Mail 2: ronda@sanchezlaw.com
E-Mail 3: maria@sanchezlaw.com
Attorneys for Plaintiff