Brown v. Ryan's Restaurant Group Inc.

Filing 4

State Court Record by Defendant Ryan's Restaurant Group Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G)(Winfield, Malissa)

Brown v. Ryan's Restaurant Group Inc.

Doc. 4 Att. 2

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IN THE CIRCUIT COURT OF ADAMS COUNTY, MISSISSIPPI Jy '-RK
\í R, cIRCUli eLl.

cOWARD .

D.C.

JAMIE A. BROWN
VS.

BY ):

NO.fO.K.V.()~.T
DEFENDANT

RYAN'S GRILL BUFFET & BAKERY
COMPLAINT

Jury Trial Demanded
COMES NOW the Plaintiff, Jamie A. Brown, and fies her Complaint against the
Defendant, Ryan's Grill Buffet & Bakery, and would respectfully show unto this Honorable
Court the following, to-wit:
i.
That Plaintiff is an adult resident citizen of

Union County, Mississippi.
II.

That the Defendant, Ryan's Grill Buffet & Baker, is a corporation doing business under
the laws of the State of Mississippi whose registered agent for service of

process is C.T.

Corporation System who can be served at 645 Lakeland East Drive, Suite 101, Flowood, MS
39232.
III.

That jurisdiction and venue are proper to this Cour.

iv.
That on or about November 16, 2009, the Plaintiff

was a customer in a restaurant owned

and operated by the Defendant in Natchez, Mississippi.

v.
That while in this store the Plaintiff went to the ladies bathroom to change her child's
diaper and fell due to the floor being wet because. ~ egligence ofthe enwo~ees of

the

Defendant.
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EXHIBIT

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BY , ~.

EDWARD C, WALK~CI 'CUlï CL::~K
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Dockets.Justia.com

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Vi.

Defendant also failed to place a waring of the dangerous condition,
VII.

That the fall and resulting damages were directly and proximately caused by the
negligence of the Defendant, and Defendant's employees in their failure to exercise a proper

degree of care in the following respects, to-wit:

A. Failing to maintain the store in a safe and reasonable maner;
B, Failing to properly patrol the store in order to keep the Plaintiff
safe;
C. Failing to properly clean and maintain store;
D. Failure to properly place a warng sign of

the known dangerous condition;

E. Failure to use reasonable care; and
F. Failure of

the Defendant to properly train its employees in how to maintain the

store in a safe maner,
VIII,

As a direct and proximate result of the gross and reckless negligence of the Defendant

and Defendant's employees in this action, Jamie A, Brown received permanent, painl and
disabling injuries which have caused her to suffer great pain, loss of enjoyment of life, loss of

wages and income, expense of medical care, emotional distress, and psychological injures. In
addition, Jamie A. Brown wil be forced to continue to suffer great pain, loss of enjoyment of
life, loss of wage-earing capacity, expense of medical care, emotional distress and psychological
injuries for the remainder of

her life.

WHEREFORE, Plaintiff demands judgment against the Defendant, Ryan's Gril Buffet &
Bakery, in an amount within the jurisdictional limits of

this Honorable Court for compensatory
the gross and reckless

damages incured by the Plaintiff, Jamie A. Brown, as the result of

negligence ofthe Defendant and Defendant's employees and for all which the Defendant, Ryan's
2

Gril Buffet & Bakery, is liable, together with interest, attorney's fees and all cour costs herein.
Respectfully submitted, this the

. AVIS, MSBN: 10111

ARE B, HANCOCK, 101203 UTLEDGE, DAVIS AND HARRS POST OFFICE BOX 29 NEW ALBANY, MS 38652 [phone]

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