IN THE DISTRICT COURT OF MARYLAND FOR BALTIMORE COUNTY

Latrice Donner *

Plaintiff *

v. *

Wal-Mart *

Defendant *
CASE NO. 123456
SERVE ON: *
THE CORPORATION TRUST
INCORPORATED *
351 WEST CAMDEN STREET
BALTIMORE MD 21201-7912 *

*
* * * * * * * * * * * * * *

COMPLAINT FOR NEGLIGENCE

Plaintiff ,Latrice Donner, (Plaintiff), through its undersigned attorney, brings this

Complaint for negligence, and in support states:

Jurisdiction and Venue

1. This Court has personal jurisdiction over Defendant Wal-Mart, pursuant to Md.

Cts. & Jud. Proc. Code Ann. 6-102 as Defendant conducts business in and is organized under

the laws of the state of Maryland.

2. Venue is proper in Baltimore County pursuant to Md. Cts. & Jud. Proc. Code

Ann. 6-201(a), as the Defendants business resides in Baltimore County, Maryland.

 Parties

3. Plaintiff is Latrice Donner who is a natural person residing at 2853 Oakridge Way 21236,

Perry Hall Maryland.

4. Defendant is Wal-Mart who is a legal person residing at 8500 Perry Hall Blvd 21128,

Perry Hall Maryland.

Facts

5. On March 2, 2017, at approximately 11:00 a.m., the Plaintiff, Latrice Donner, was
shopping in the housewares sections of the Perry Hall store and was passing through the
furniture aisle, when she noticed that the item she wanted to purchase, a beanbag chair,
was on the top shelf. The plaintiff notified a female employee, who appeared harried, to
assist her in housewares and returned to the aisle, alone, where she continued to wait for
ten (10) more minutes. When no assistance had arrived, the plaintiff, Latrice Donner,
attempted to reach for the bean bag chair herself by climbing on the edge of the first
shelf, when, while she was pulling down the bean bag chair from the third shelf, the
entire third shelf collapsed, resulting in the bean bag chair, two wooden chairs, and a
small wooden desk to come down, crashing, on top of her. As the plaintiff, Latrice
Donner, called for help, two other customers come to her assistance, Betty Thomas and
Bernard Cunningham. The first customer, Betty Thomas, left the scene to notify the
Manager, while the second customer, Bernard Cunningham had stayed with the Plaintiff.
Before the Manager had arrived, a stockboy named Tony Myers arrived on the scene,
took a look at the shelf, and said I told them we shouldnt be putting that desk up there.
The manager had then arrived, apologized, called for an ambulance, and summoned
security, who has completed a written report. During the time Tony Myers was
questioned, he admited that he stated this to his supervisor, Henry, when they were
putting up the shelf the day before that they should not put the desk on the third shelf.
Henry was contacted but refused to communicate details.
 Count One
Negligence

6. The allegations of paragraphs 1 through 5 are incorporated herein by reference.

7. The Plaintiff, Latrice Donner, adopts and incorporates all of the facts and allegations set
forth above as if fully set forth herein. As a direct and proximate result of the aforesaid
event, which was caused by the negligence of the defendant, Wal-Mart, the Plaintiff,
Latrice Donner, who was forced to assist herself when no help had arrived, was suddenly
and forcefully thrown against the floor, thereby causing the plaintiff, Latrice Donner, to
suffer severe pain and injury, including but not limited to, her broken rib, multiple
bruises, and a minor but painful concussion, all of which have caused her great pain and
mental anguish. As a further direct and proximate result of the negligence of the
Defendant, Wal-Mart, the Plaintiff, Latrice Donner, has been forced to expend large sums
of money for hospitalization, x-rays, nurses, medical treatment and for medicine for the
treatment of the aforesaid injuries to herself. As a further direct and proximate result of
the negligence of the Defendant, Wal-Mart, the Plaintiff, Latrice Donner, was forced to
lose time from her employment and has suffered a loss of wages for which she seeks
remuneration.

WHEREFORE Plaintiff demands judgment against the Defendant in the amount of One

Thousand Eight Hundred Sixty Nine Dollars and Sixty Nine Cents ($1,869.69) in compensatory

damages, plus costs, and post-judgment interest, along with any other relief that the Court

may find is just and equitable.

Respectfully Submitted:

Patricia Bienkowski
_____________________________________
Dale & Chip, P.A.
7200 Sollers Point Road
Perry Hall, Maryland 22222
(p) 410-555-1212
(e) dchip@DaleandChip.com

Attorney for Plaintiff