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Connie Hoidas and James Hoidas v. Wal-Mart Stores

November 14, 2011

CONNIE HOIDAS AND JAMES HOIDAS,
PLAINTIFFS,
v.
WAL-MART STORES, INC.,
DEFENDANT



The opinion of the court was delivered by: Judge Hibbler

TLMS

FILED JANUARY 13, 2011

MICHAEL W. DOBBINS CLERK, U.S. DISTRICT COURT

JURY DEMAND SECOND AMENDED COMPLAINT

NOW COME the Plaintiffs, CONNIE HOIDAS and JAMES HOIDAS, by and through their attorneys, KEITH L. DAVIDSON and GOLDBERG & GOLDBERG, and complaining of the Defendant, WAL-MART STORES, INC., allege as follows:

Count I (Personal Injury action by Plaintiff Connie Hoidas)

1. At all times complained of, Defendant WAL-MART STORES, INC. was and is a corporation organized under the laws of the State of Delaware, licensed to do business in the State of Illinois, and was and still is doing business in Cook County, Illinois.

2. This court has jurisdiction of the action under 28 U.S.C. §§ 1330 and 1332. Venue is proper in this court under 28 U.S.C. §1391.

3. On or about May 30, 2009, Defendant WAL-MART STORES, INC. owned, operated, managed and maintained a place of business, the structures, the land and the premises located at 10260 South Harlem Avenue, Bridgeview, Illinois, 60455. Said premises included a large general merchandise store ("the store") and parking areas, including a main parking lot ("the parking lot").

4. At said time and place, Plaintiff CONNIE HOIDAS was lawfully upon said premises.

5. At all times pertinent hereto, it was the duty of Defendant WAL-MART STORES, INC. to exercise a reasonable degree of care and caution in the ownership, operation, management, maintenance and upkeep of said premises for the safety of persons, including Plaintiff CONNIE HOIDAS, who were lawfully on the premises.

6. At all times herein, referred to, it was the duty of Defendant WAL-MART STORES, INC. to exercise a reasonable degree of care and caution in the inspection of their premises whereby they would have or could have discovered and corrected a dangerous pothole that caused plaintiff's injury.

7. At the aforesaid time and place, Plaintiff CONNIE HOIDAS was severely injured when she was caused to fall by reason of a dangerous pothole that Defendant WAL-MART STORES, INC. allowed to exist in the parking area at and on said premises.

8. At said time and place, notwithstanding the aforesaid duties, Defendant WAL-MART STORES, INC., by and through its agents and/or servants and/or employees, was then and there guilty of ...


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