Kim Lohman
456 Forest Hills
Queens NY 11550
(718) xxx-xxxx
SUPERIOR
COURT OF THE STATE OF NEWYORK COUNTY OF Kings Brooklyn
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Kim Lohman
Plaintiffs,
v.
Wilber Hall Law school, Mr. John
doe and Mrs. Jane doe, Secretary
Defendants
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CASE NO: 105-831
COMPLAINT FOR
NEGLIGENCE
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Plaintiff complains and for causes
of action alleges as follows:
1. Plaintiff, Kim Lohman, is an
individual and is
now, and at all times mentioned in this complaint is, a
resident of Brooklyn County, NewYork.
2. Defendant Wilbert Hall Law School
is now, and at all times
mentioned in this complaint is, a Law school organized and
existing under the laws of the State of New York, with its
place of business in Nassau County,NewYork.
3. Plaintiff does not know the true
names of defendants
and therefore sues them by those fictitious names. And alleges, that each of
those defendants was in some manner negligently and proximately
responsible for the events and happenings alleged in this
complaint and for plaintiff's injuries and damages.
4. Tuesday, Lohman accompanied Tony
Raiford to the second floor of Wilbert Hall Law School Annex.
5. Raiford had appointment with
drafting instructor; Appointment was at 4:30.
6. At 5:00 Secretary left. Lohman,
Raiford, and instructor were the only one on premises.
7. Lohman heard a crash on S.W.
second ave.
8. A door was open to an office at
the front of building.
9. Lohman went behind the desk to see what
happened.
10. Lohman tripped on a cord, bumped
into a desk as she fell.
11. Scissors that was on the edge of
the desk fell onto the floor and Lohman landed on one of the blades. And
discovered she could not move her right arm.
13.
Lohman went to the hospital, her arm was broken, and there was a deep
gash in her hand that required seven stitches.
Plaintiff, demands judgment against defendants,
and each of them, for the following:
14. Medical bills amounting $665.47.
15. Loss to perform tasks required
as medical student.
16. Costs of this action; and
17. Any other and further relief
that the court considers
proper.
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DATED: _______________
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__________________________________________
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(Signature)
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VERIFICATION
I, ___, am a ___in the
above-entitled action. I have read the foregoing ___and know the
contents thereof. The same is true of my own knowledge, except as to those
matters which are therein alleged on information and belief, and as to those
matters, I believe it to be true.
I declare under penalty of perjury
that the foregoing is true and correct and that this declaration was executed
at Kings County, Brooklyn.
DATED: _________________
___________________________________
Respectfully submitted,
Marilyn
& Bridgett, LLC
___________________________
Marilyn & Bridgett
Kings Inner Harbor Center
400 East Pratt Street, 8th Floor
Brooklyn, New York 21201
(516)-xxx-xxx
