HomeMy WebLinkAbout94-03365
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JUL 19
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b. Failing to provide Plaintiff with a safe environment
within which to work,
c. Fai ling to take steps in order to prevent the accident,
including failing to take steps to properly inspect and
repair or clean the ladder or to stop Plaintiff from
using the ladder;
d. Failing to inspect the car and its ladder,
e. Failing to take adequate and preventative measures to
corract the dangerous, or potentially dangerous,
conditionsl and
f, Fa i ling to properly supervise and warn the Plaintiff
so he would not be injured.
18, 'rhe aforementioned accident resulted solely from the
negligence, c8ulessness and recklessnesB of the Defendant as
aloraaaid, and weB not due to any act, or failure to act, on the part
of Plaintiff.
19. As a direct and proximate result of Defendant's aforesaid
negligencB, calslsssness and recklessness, Plaintiff, Fred W. Zeigler,
HlllltalnBti IlIllnetouB Bevere injuries and symptoms, including, but not
Ilmltlld to, the following.
a. I,umbo-sacral strainl
b. Iletlliated nucleus pulposus and/or a bulging disc at L.
4/L-5,
c, Severe contusion with associated pain in his back; and
d, Various other C0l1tulliol111 and abrasiol1s.
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20. As a result of Defendant.s negligence, Plaintiff incurred
injuries which were and are severe, permanent and disabling in nature.
21. As a resul t of his injuries and Defendant's negligence,
Plaintiff Fred W. Zeigler suffered and will continue to suffer in the
future, severe physical pain, suffering, mental 'lnguish, humiliation
and loss of life's pleasures.
22. As a result of his injuries and Defendant's negligence,
Plaintiff, Fred W. Zeigler, has suffered physical impairments which
have, and may continue to, hinder all or substantially all, of the
material duties that constitute his usual and customary daily
activities.
23. As a result of his injuries and Defendant. s negligence,
Plaintiff Fred W. Zeigler has suffered and will continue to suffer a
severe and permanent loss of earnings and impairment of his earning
capacity.
24. As a result of his injuries and Defendant's negligence,
Plaintiff Fred W, Zeigler has been, and will be. obligated to receive
and undergo medical attention, care and therapy. and he has incurred
various expenses for said medical treatment and therapy, and expenses
related thereto, and will be obligated to expend such sums, or incur
such expenses, for an indefinite time in the future.
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