Form 3:01

Complaint in a Trip-and-Fall Case [Illinois Rules]

[Caption]
COMPLAINT
COMES NOW the Plaintiff,
, by and through her attorneys,
, and for her
Complaint against the Defendant,
, states as follows:
1. That on or about December 3, 2004, the Defendant owned, managed, operated,
maintained, and controlled, both directly and indirectly, individually and through its
agents, servants, and employees, a certain shopping center known as
and
located at
, Illinois.
2. That on and before that date, the Defendant invited the general public, including the
Plaintiff, to enter said shopping center for the purpose of the operation of the shopping
center.
3. That it then and there became and was the duty of the Defendant, individually and by and
through its agents, servants and employees, to keep the premises in a reasonably safe
condition for the Plaintiff and other persons lawfully in and about the shopping center,
and further, not to create or allow any dangerous conditions to exist on or about the
premises.
4. That at the above date and place, the Plaintiff,
, was lawfully on the subject
premises, walking in the shopping center.
5. That, disregarding its stated duty, Defendant, by its agents, employees and servants,
committed the following acts and omissions:
a. failed to provide a good, safe and proper place for the Plaintiff to be, use, occupy and
walk on while on the subject premises;
b. allowed and permitted the subject premises to become and remain in a dangerous
condition;
c. failed to inspect the premises to be certain that they were in good, safe and proper
condition;
d. failed to warn the Plaintiff and others of the unsafe, defective and dangerous
condition of the subject premises;
e. failed to safeguard its customers by maintaining equipment in an unsafe location;
f. failed to warn customers of obstacles in walkways;
g. failed to warn customers of protruding parts on equipment located in customer
walkways.
6. That as a direct and proximate result of one or more of these negligent acts and/or
omissions of the Defendant, individually and by and through its agents, servants, and
employees, the Plaintiff was caused to fall.
7. That as a direct and proximate result of this fall, the Plaintiff has suffered severe,
extensive and permanent injuries, both externally and internally, and was and will
continue to be hindered in attending to usual duties and affairs, and has lost and will in
the future lose the value of this time. As a result of those injuries, the Plaintiff has become
liable for large sums of medical bills and will expend and/or will become liable for
additional medical bills in the future.
8. That as a direct and proximate result of this fall, the Plaintiff has suffered loss of income.

WHEREFORE, the Plaintiff,

, prays that this court enter its judgment against the
Defendant,
, in a sum in excess of $50,000 plus Court costs.
Respectfully submitted,
[Moving Party]
By
One of its attorneys
[Certificate of Service]