Complaint and Discovery
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
VERIFIED
Mike Turner,
COMPLAINT
Plaintiff,
~Against~
Index No:
Daytime Bakery Company
Defendants
REQUEST FOR ANSWERS TO INTERROGATORIES. Plaintiff MIKE TURNER, by his attorneys, J.J. LEGAL & ASSOOCIATES complaining of the Defendants herein, upon information and belief respectfully alleges as follows:
Plaintiff MIKE TURNER is a resident of the City, County and State of New York.
Plaintiff MIKE TURNER is an able bodied individual not prone to falling and fell because of the snow that had accumulated on the sidewalk.
Plaintiff MIKE TURNER alleges that while walking in front of the Daytime Bakery on a cold December day, Mr. Turner slipped and fell because of the snow that had accumulated on the sidewalk.
4.
The fall caused Plaintiff MIKE TURNER to break his left leg and left arm which required him to seek medical attention.
5.
The medical examination required a $5,000 outlay by Plaintiff MIKE TURNER and may require future medical follow up treatment.
Defendant DAY TIME BAKERY left their sidewalk in front of their store covered in snow
7.
Defendant DAY TIME BAKERY has a legal responsibility based on a city ordinance to keep the sidewalks in front of their stores reasonably clear from all hazards.
8.
Defendant DAY TIME BAKERY had not shoveled their sidewalk for at least four days.
9.
Defendant DAY TIME BAKERY made an inadequate effort to...
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