Sample Slip and Fall Complaint

{LAW FIRM NAME}
{Address}
{City}, {State} {ZIP}
{Telephone:}
{Facsimile: }

{Lawyer Name (Bar No.)}
Email: {}

Attorney for Plaintiff

In the Superior Court of the state of Arizona
In and for the County of Maricopa

Plaintiff, by and through counsel undersigned, and for [his/her] Complaint against Defendants, alleges as follows:

PARTIES, JURISDICTION AND VENUE

1. Plaintiff __________ is and was a resident of Maricopa County, Arizona at all relevant times.
2. Defendant [parent name of retail/business establishment] is now, and at all times relevant was, a [corporation or other business organization] organized and existing under the laws of the State of Arizona, with its place of business in Maricopa County, Arizona.
3. Defendant [parent name of retail establishment] owns, operates and does business as “[name of retail/business establishment]” located at _____________________, _________, Arizona, and is in the business of [describe type of business] selling to public.
4. At all material times, Defendant includes and included any and all parents, subsidiaries, affiliates, divisions, franchises, partners, joint ventures, and organization units of any kind, predecessors, successors and assigns and their officers, directors, employees, agents, representatives and any and all other persons acting on their behalf.
5. At all material times, each of the Defendant was the agent and employee of every other Defendant in doing the events described and was at all times acting within the purpose and scope of such agency and employment and are vicariously liable under the theory of respondeat superior for the actions and inactions of their employees and contractors.
6. Defendants John Does and Jane Does 1-10, ABC Corporations 1-10, Limited Liability Companies and/or partnerships 1-10 are persons and entities whose true identities are unknown to Plaintiff, who together with named Defendants contributed to causing Plaintiff’s injuries and damages. Plaintiff will amend [his/her] Complaint when the true names of those Defendants become known.
7. Jurisdiction and venue are proper as the events giving rise to Plaintiff’s Complaint occurred in Maricopa County, Arizona and the amount in controversy exceeds the minimal jurisdictional requirements of this Court.
8. The amount of Plaintiff’s damages qualifies this matter as a Tier [1, 2 or 3] case in accordance with Rule 8(b)(2) of the Arizona Rules of Civil Procedure.

GENERAL ALLEGATIONS

9. Plaintiff incorporates by reference all prior allegations contained in this Complaint.
10. On or about _____________, at approximately _____, Plaintiff was on the premises of Defendant store for the purpose of purchasing various items. After entering the store, Plaintiff proceeded to the ____________ [aisle/section] when suddenly and without warning Plaintiff slipped on an unknown substance and fell violently to the floor.

NEGLIGENCE

11. Plaintiff incorporates by reference all prior allegations contained in this Complaint.
12. Defendant, as owners and operators of the store, or through its agents or employees, negligently failed to maintain the floor of the store in a reasonably safe condition.
13. Defendant, as owners and operators of the store, or through its agents or employees, allowed a slippery substance to come into contact with and remain on the floor of the store when Defendant, or its agents or employees, knew, or in the exercise of reasonable care should have known, that the substance created an unreasonable risk of harm to customers in the store.
14. Defendant, as owners and operators of the store, or through its agents or employees, failed to warn Plaintiff of the danger presented by the presence of the slippery substance on the floor.
15. Defendant failed to provide a nonslip surface on the floor of the store.
16. Defendant failed to otherwise exercise due care with respect to the matters alleged in this Complaint.
17. As a direct and proximate result of the negligence of Defendants as set forth above, Plaintiff slipped and fell while in the store.
18. As a further direct and proximate result of the negligence of Defendants set forth above, Plaintiff sustained serious injuries and damages.

DEMAND FOR JURY TRIAL

19. Plaintiff demands a trial by jury on all issues so triable.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests that the Court enter judgment against Defendant as follows:

1. For Plaintiff’s general and special damages;
2. For Plaintiff’s costs incurred in pursuing these claims;
3. For pre- and post-judgment interest to the extent provided by law;
4. For such further relief as the Court deems just and fair.

DATED this ____ day of _____________, _____.