Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 12 of this Complaint.
13. Defendants conduct in maintaining an electrical system in a public area constituted an abnormally dangerous activity which exposed Plaintiff to an unreasonable risk of harm.
14. At all relevant times, Defendant had control over the abnormally dangerous activity of maintaining the electrical system.
15. As set forth above, Plaintiff sustained injury as a direct and proximate cause of this unreasonably dangerous activity.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of FIVE MILLION DOLLARS ($5,000,000.00), plus interest, costs and any other relief this court deems appropriate.
Respectfully submitted, MILLER & ZOIS, LLC Ronald V. Miller, Jr.
Laura G. Zois
Empire Towers, Suite 615 7310 Ritchie Highway
Glen Burnie, Maryland 21061 (410)553-6000
Counsel for Plaintiffs PLAINTIFFS REQUEST FOR JURY TRIAL
Plaintiff pursuant to Maryland Rule 2-325, prays a trial by jury on all issues.
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Falling off a diving board at a public pool*
My 8 year son was climbing the ladder of the high dive at a public pool when he apparently slipped on the step and fell 10 ft. to the concrete*. He suffered a fractured skull*, stitches to the head, a broken arm and multiple cuts/scraps. He will be unable to participate in any sports for 9-12 months. He will not be able to participate in physical education in school for the first 6 months of the school year. Most importantly, our vacation (booked for next week) had to be canceled. Do I have a personal injury case here? I am grateful my son is alive, however, I am wondering at what point does an accident on public property become a liability issue? (pool ; concrete ; fractured skull nepeo oc epena; stitches )
Is a village or town responsible for their parks?
I went to a public park maintained by the village for a village-spon-sored event and while walking on their paved walking path slipped and fell on their path resulting in pain and suffering in my right hip and back. The path was not only wet and muddy but was green and slimy* with some kind of moss*. Shouldnt they have posted signs that day saying that pathways can be dangerous when wet? Are they responsible for my injury? Can I sue them for pain, suffering, and Dr. bills? (slimy -; moss )
Product liability or malpractice?
My apartment owner engaged in a re-plumb construction* with a plumbing service* corporation in December 2002. The plumbing company made a mistake and connected the hot water pipe and cold water pipe wrongly (cross-connected) and now I am exposed to scalding* water when-ever I turn on the faucet*. If I am injured by this faucet defect, is the plumb-ing company responsible for product liability or malpractice? The owner has no desire to negotiate with the constructor since he thinks I should put up* with the situation. (re-plumb construction - py; plumbing service ;
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scalding ; faucet ; to put up with .-.)
Slip and fall/Premises liability
A close friend of mine needed a place to stay for a few days. My husband and I offered her to stay with us. We currently rent from a private homeowner. No signed lease exists, everything was done on a handshake. My friend asked to use our shower and, of course, we agreed. My husband mentioned for her to be careful, as it could get slippery because of no rubber mats in the shower. She slipped and fell, claiming she could not move her arm. I took her to the Emergency Room where they did x-rays, and advised her that it was not broken, just dislocated. They relocated it, then put her in a sling. 5 days later, she follows up with a surgeon. Afterwards, she calls me to say that according to the surgeon, her arm was fractured and there might be some permanent damage, which will lead to future surgery. She then proceeds to tell me that she is considering filing an injury claim against our landlord and/or his insurance company. How will this affect us as tenants, and are we held responsible for having no mats in the shower?
Paintball guns
I was with a group of people who had been drinking. They decided to go out and shoot their paintball guns inside city limits at signs and buildings and other things. I was sober so I decided to drive them instead of letting them drive. At one point they fired their guns at a vehicle and there were people standing around. The cops showed up and charged the shooter with vandalism and assault. They also charged me with the same charges because I was driving. What should I do?
GLOSSARY
a civil wrong
a tort
action
adversarial ( )
adversary
assault , -
battery , ,
to breach duty
burden of proof
causation , -
compensatory damages
to construe
contractual relations
determination
disabled ;
to dispose of
emotional harm, mental distress
forceable
fraud
fraudulent misrepresentation ,
frivolous ,
future expected losses
grievance
injunction
injunctive relief
injury , ,
inquisitorial
invasion of privacy
liability insurance
libel
loss of earning capacity
malice (intent)
medical malpractice claim
medical malpractice () -
misstatement ,
to mug ( )
negligence ,
permanent injunction
premises liability
proceeding(s)
products liability
punitive damages -
to reach a settlement
remedies
revenues
to seek damages
slander
standard/burden of proof
strict liability tort
tort feasor ,
trespass
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umpire ,
vindication , (), -
PART VI
