IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT

IN AND FOR ORANGE COUNTY, FLORIDA

LOWELL ORLOFF, )

Plaintiff, )

-vs- ) CASE NO.: 10-1234-moot

A & B CORPORATION, INC. dba THE )

WEAR HOUSE, a corporation authorized )

And doing business in the State of Florida, )

Defendant. )

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FALL- DOWN NEGLIGENCE COMPLAINT

Plaintiff, LOWELL ORLOFF, sues Defendant A&B CORPORATION, INC. dba THE WEAR HOUSE and alleges:

1. This is an action for damages that exceed Thirty Thousand Dollars ($30,000).
2. On January 3, 2019, Defendant was the owner and in possession of a building at 123 Main Street, Orlando,
Orange County, Florida that was used as a retail clothes store.
3. At that time and place the Plaintiff went onto the property in response to a business invitation.
4. Defendant negligently maintained the floor on the property by failing to repair a piece of torn, frayed carpeting
so that Plaintiff fell on the property.
5. The negligent condition was known to Defendant or had existed for a sufficient length of time so that Defendant
should have known of it.
6. As a result Plaintiff was injured in and about his body and extremities, suffered pain therefrom, incurred medical
expenses in the treatment of the injuries, and suffered physical handicap, and his working ability was impaired;
the injuries are either permanent or continuing in nature and Plaintiff will suffer the losses and impairment in
the future.

WHEREFORE Plaintiff demands trial by jury and judgment for damages against the Defendant as follows:

1. Medical costs of $26,000.00;

2. Lost wages of $12,000.00;
3. Pain and suffering in an amount to be determined at trial;
4. Attorney’s fees and court costs; and
5. Any and all other forms of relief that this Court deems just and proper.
Dated on this 15th day of January 2020.

_____________________________
Florida Lawyer, Esquire
Dewey, Cheatem and Howe, P.A.
1234 Crooked Street
Orlando, FL 32808