Logan Reeve (0023224)

REEVE, PEARSON & SPECTRE

3820 Legal Lane
Stoneville, Caper 00026
(555)555-5555
loganreeve@gmail.com
Attorney for Plaintiff
IN THE THIRD DISTRICT COURT, SALT LAKE DEPARTMENT
IN AND FOR SALT LAKE COUNTY, STATE OF UTAH
CANDACE CUSTOMER,

COMPLAINT

Plaintiff,

(JURY DEMANDED)

v.
OWEN OWNER,

Case no.____________
Judge______________

Defendant.
Plaintiff, Candace Customer, by and through her counsel of record, hereby
complains against Defendant, Owen Owner, as follows:
PARTIES
1. Candace Customer, (hereinafter Plaintiff) is a resident of Salt Lake County,
State of Utah.
2. Owen Owner, (hereinafter Defendant) is believed to be a resident of Davis
County, State of Utah.

JURISDICTION AND VENUE

3. The Third Judicial District Court in and for Salt Lake County, State of Utah,
has jurisdiction of the claims asserted below pursuant to the pursuant to the
provision of 78A-5-102(1), Utah Code Ann.
4. Venue is properly laid before the Third Judicial District Court in and for Salt
Lake County, State of Utah, pursuant to the provisions of 78B-3-3079(1)(a),
Utah Code Ann., in that the causes of action alleged below arose within Salt
Lake County, State of Utah.
GENERAL ALLEGATIONS OF FACT
5. On Thursday December 7, 2000 at approximately 10:15 a.m., Plaintiff entered
Speedy Donuts.
6. Defendant opened his shop at 8: a.m. and had been helping twelve customers
before Plaintiff arrived.
7. Plaintiff walked in line, ordered donuts, and paid for them upon receipt.
8. The weather conditions of the day were that of ten inches of snow from a
storm that had stopped at approximately 5:30 a.m.
9. Defendant had a rug in the front entryway for customers to wipe their feet off
on to prevent slipping in the store.
10. Plaintiff did not see the rug at anytime while inside the shop.
11. As a result of the weather conditions there was a puddle of water on the floor
inside of the shop.
12. As Plaintiff turned to leave after purchasing a dozen donuts, Plaintiff slipped
on the puddle and hit her head on the concrete floor of the shop which caused
her to become unconscious.
13. Plaintiffs injuries as a result of the fall were that of a concussion and required
Plaintiff to remain under hospital care overnight.
14. Plaintiff was also prescribed a mild painkiller while hospitalized.

FIRST CLAIM FOR RELIEF AGAINST DEFENDANT

(NEGLIGENCE)
15. Plaintiff, by and through this reference, hereby incorporates paragraphs one
through fourteen above as if fully set forth herein.
16. Defendant owed Plaintiff a duty to keep his shop clear of potential dangers
such as slips and falls or any potentially hazardous conditions.
17. On December 7, 2000 Defendant failed to perform said duty negligently by
not keeping the shop free of hazardous conditions.
18. By conducting himself as described above, Defendant breached his duty to
Plaintiff.
19. As the direct cause of the Defendants negligence, Plaintiff has suffered,
continues to suffer, and will suffer in the future, injuries, including pain of the
head and body and has incurred and will continue to incur expenses for
medical attention and treatment and lost wages.
JURY TRIAL DEMANDED
Plaintiff hereby requests that this matter be tried before a jury, and Plaintiff has
submitted the required jury fee herewith.
REQUEST FOR RELIEF
WHEREFORE, Plaintiff requests relief against Defendant as follows:
1.
2.
3.
4.
5.

General damages for pain and suffering in an amount to be proven at trial;

Past and future medical expenses in an amount to be proven at trial;
Past and future economic loss in an amount to be proven at trial;
Permanent impairment and disability in an amount to be proven at trial;
Costs of suit and such further relief as the Court deems just and proper.

Dated this

day of ________, 2016.

REEVE, PEARSON & SPECTRE

Logan Reeve
Attorney for Plaintiff

This Document prepared and submitted by:

Logan Reeve (0023224)
REEVE, PEARSON & SPECTRE
3820 Legal Lane
Stoneville, Caper 00026
(555)555-5555
loganreeve@gmail.com
Attorney for Plaintiff