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.

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HC\,t:IV1:U
AND FILED
JUL 2 2 2010

Doc. 4 Att. 5

BY ~ D.C. JAMIE A. BROWN PLAINTIFF

IN THE CIRCUIT COURT OF ADAMS COUNTY. MISSf§~tI\lf?l~IT CLERK

VS. NO.I0-~-0059-J
RYAN'S RESTAURANT GROUP, INC. d/b/a RYAN'S GRILL BUFFET & BAKERY

DEFENDANT

AMENDED COMPLAINT
Jury Trial Demanded
COMES NOW the Plaintiff, Jamie A. Brown, and files her Amended Complaint against

the Defendant, Ryan's Restaurant Group, Inc., d/b/a Ryan's Gril 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 Restaurant Group, Inc. d/b/a Ryan's Grill Buffet & Bakery, 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
e of the negligence of the employees of the Defendant.
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BY D.C.

EDWARD C. W KER, CIRCUIT CLERK

Dockets.Justia.com

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, painful and

disabling injures 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 injuries. In

addition, Jamie A. Brown wil be forced to continue to suffer great pain, loss of enjoyment of
life, loss of wage-earng 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 Restaurant
Group, Inc. d//a Ryan's Gril Buffet & Bakery, in an amount within the jurisdictional limits of

this Honorable Cour for compensatory damages incurred by the Plaintiff, Jamie A. Brown, as
the result of the gross and reckless negligence of

the Defendant and Defendant's employees and
2

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for all which the Defendant, Ryan's Restaurant

Group, Inc. d//a Ryan's Grill Buffet & Bakery,

is liable, together with interest, attorney's fees and all court costs herein.

Respectfly submittd, this the /f/A day O~l o.

V ALARIE B. HANCOCK, 101203 RKUTLEDGE, DAVIS AND HARRS POST OFFICE BOX 29 NEW ALBANY, MS 38652 [phone]

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