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4:47 PM Wed Feb 28 * @ 100% mycourses.spcollege.edu IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIRCUIT
4:47 PM Wed Feb 28 * @ 100% mycourses.spcollege.edu IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIRCUIT CIVIL NO. HOMER SIMPSON & MARGE SIMPSON, Plaintiffs, V. HAPPY SUMO, INC., JIRO ONO, AKIRA SHUH, & JUBI SOUS. Defendants. of PLAINTIFFS' COMPLAINT facts Plaintiffs, HOMER SIMPSON, and MARGE SIMPSON sue Defendants, HAPPY SUMO, INC., a Florida corporation, JIRO ONO, an individual, AKIRA SHUH, an individual, and JUBI SOUS, an individual, and hereby allege: COUNT 1 -NEGLIGENCE Statement of: 1. Pursuant to F.S. $ 26.012(2)(a), this court has jurisdiction over civil matters that exceed the value of $30,000. 2. This is an action for damages which exceed the sum of $30,000.4:47 PM Wed Feb 28 100% mycourses.spcollege.edu SOUS, an individual, and hereby allege: COUNT 1 - NEGLIGENCE Statement of: 1. Pursuant to F.S. $ 26.012(2)(a), this court has jurisdiction over civil matters that exceed the value of $30,000. 2. This is an action for damages which exceed the sum of $30,000. Statement of: 3. At all times material hereto, the Plaintiffs, HOMER SIMPSON, and MARGE SIMPSON, a married couple, were residents of Pinellas County, Florida. 4. Defendant, HAPPY SUMO, INC., was and is a for-profit corporation incorporated in Florida with its principal place of business located in Pinellas County, Florida. 5. At all times material hereto, Defendants, JIRO ONO, AKIRA SHUH, and JUBI SOUS were residents of Pinellas County, Florida. 6. On or about January 1, 2021, the Plaintiffs, HOMER SIMPSON, and MARGE of facts Instructions of 1. Read the Complaint (if this is too small, use the facts other one without the boxes to read. S 2. Fill in the boxes, identifying the parts of the Complaint. I have provided a prompt for some. For those without prompt, answer this: "What is4:47PM Wed Feb 28 * @ 100% mycourses.spcollege.edu were residents of Pinellas County, Florida. 6. On or about January 1, 2021, the Plaintiffs, HOMER SIMPSON, and MARGE of facts Instructions of 1. Read the Complaint (if this is too small, use the facts other one without the boxes to read. S 2. Fill in the boxes, identifying the parts of the Complaint. I have provided a prompt for some. For those without a prompt, answer this: "What is Facts showing this?" DUTY: 3. Draw arrows to or list the paragraph numbers as 9. Defendants knew or should have known that if not, prepared .properly, fugu (containing you answer that coincide with the description. puffer fish) zar "For example, there should be an arrow between 10. Defendants entrusted the preparation of Plaintiff, HOMER SIMPSON's order the first box on this page and paragraphs I & 2! the restaurant' Mark any typos or errors that you see as you go. JIRO ONO, the master chef of Defendant, HAPPY SUMO, INC. 11. Defendants served Plaintiff, HOMER SIMPSON, the fugu prepared by the restaurant's sous chef and Defendant, JUBI SOUS. 12. Upon consumption of the fugu, Plaintiff, HOMER SIMPSON, was informed by Defendant, AKIRA CUTIT that he conous puffer fish and needed to be rushed4:47 PM Wed Feb 28 100% mycourses.spcollege.edu DUTY: 3. Draw arrows to or list the paragraph numbers as 9. Defendants knew or should have known that if not, prepared .properly, fugu (containing you answer that coincide with the description. puffer fish) can be toxic to humans upon consumption "4. For example, there should be an arrow between 10. Defendants entrusted the preparation of Plaintiff, HOMER SIMPSON's order pf fusp too 2! the first box on this page and paragraphs T the restaught park any typos or errors that you see as you JIRO ONO, the master chef of Defendant, HAPPY SUMO, INC. 11. Defendants served Plaintiff, HOMER SIMPSON, the fugu prepared by the restaurant's sous chef and Defendant, JUBI SOUS. 12. Upon consumption of the fugu, Plaintiff, HOMER SIMPSON, was informed by Defendant, AKIRA SHUH, that he had consumed poisonous puffer fish and needed to be rushed Facts showing to the hospital to receive emergency care. BREACH: 13. Plaintiff HOMER SIMPSON was transported to Springfield Hospital via ambulance and he and Plaintiff MARGE SIMPSON were told that he had twenty-two hours to live. 14. As a direct and proximate result of these negligent acts of the Defendants, HAPPY SUMO, INC., JIRO ONO, AKIRA SHUH, and JUBI SOUS, the Plaintiff, HOMER SIMPSON, has and will continue to suffer mental, physical, and monetary injuries, including but not limited to pain and suffering, medical expenses, and lost wages.4:47 PM Wed Feb 28 * 100% mycourses.spcollege.edu 12. Upon consumption of the fugu, Plaintiff, HOMER SIMPSON, was informed by Defendant, AKIRA SHUH, that he had consumed poisonous puffer fish and needed to be rushed Facts showing to the hospital to receive emergency care. BREACH: 13. Plaintiff HOMER SIMPSON was transported to Springfield Hospital via ambulance and he and Plaintiff MARGE SIMPSON were told that he had twenty-two hours to live. 14. As a direct and proximate result of these negligent acts of the Defendants, HAPPY SUMO, INC., JIRO ONO, AKIRA SHUH, and JUBI SOUS, the Plaintiff, HOMER SIMPSON, has and will continue to suffer mental, physical, and monetary injuries, including but not limited to pain and suffering, medical expenses, and lost wages. Facts showing Facts showing CAUSATION: 2 DAMAGES: 15. As a direct and proximate result of the negligent acts of Defendants, Plaintiff MARGE SIMPSON, has suffered serious injury, including but not limited to anxiety, altered sleeping habits, persistent headaches, and the inability to lead a normal life; and has in the past and will in the future suffer mental and physical pain and suffering. 16. Plaintiff MARGE SIMPSON is and will continue to be required in the future to spend4:47 PM Wed Feb 28 * @ 100% mycourses.spcollege.edu 15. As a direct and proximate result of the negligent acts of Defendants, Plaintiff MARGE SIMPSON, has suffered serious injury, including but not limited to anxiety, altered sleeping habits, persistent headaches, and the inability to lead a normal life; and has in the past and will in the future suffer mental and physical pain and suffering. 16. Plaintiff MARGE SIMPSON is and will continue to be required in the future to spend large sums of money for medical care to treat the above injuries. WHEREFORE, Plaintiffs, HOMER SIMPSON, and MARGE SIMPSON demand judgment against the Defendants, HAPPY SUMO, INC., JIRO ONO, AKIRA SHUH, and JUBI SOUS, for all economic and non-economic damages to which they are entitled, the cost of this action, and general relief. COUNT 2 -LOSS OF CONSORTIUM 17. Plaintiffs re-allege and incorporate by reference herein Paragraphs 1-7, and 14-16, inclusive, of this Complaint. 18. On or about January 1, 2021, the Plaintiffs, HOMER SIMPSON, and MARGE SIMPSON were patrons at Defendant, HAPPY SUMO, INC.'s, place of business. After the above-referenced action at Defendant, HAPPY SUMO, INC., the Plaintiff, HOMER SIMPSON, was examined at Springfield Hospital, and was diagnosed with twenty-two hours to live since the Plaintiff, HOMER SIMPSON, had consumed a deadly venomous pufferfish.4:47 PM Wed Feb 28 100% mycourses.spcollege.edu action, and general relief. COUNT 2 -LOSS OF CONSORTIUM 17. Plaintiffs re-allege and incorporate by reference herein Paragraphs 1-7, and 14-16, inclusive, of this Complaint. 18. On or about January 1, 2021, the Plaintiffs, HOMER SIMPSON, and MARGE SIMPSON were patrons at Defendant, HAPPY SUMO, INC.'s, place of business. After the above-referenced action at Defendant, HAPPY SUMO, INC., the Plaintiff, HOMER SIMPSON, was examined at Springfield Hospital, and was diagnosed with twenty-two hours to live since the Plaintiff, HOMER SIMPSON, had consumed a deadly venomous pufferfish. 19. Defendants knew or should have known that sending a family and/or patron to the Emergency Room after telling them the patriarch of the family could die would cause distress. 20. If not for Defendants' failure to safely prepare and serve fugu, Plaintiff, HOMER SIMPSON, would not have been rushed to the Springfield Hospital via ambulance and Plaintiff, 04:47 PM Wed Feb 28 * @ 100% mycourses.spcollege.edu was examined at Springfield Hospital, and was diagnosed with twenty-two hours to live since the Plaintiff, HOMER SIMPSON, had consumed a deadly venomous pufferfish. 19. Defendants knew or should have known that sending a family and/or patron to the Emergency Room after telling them the patriarch of the family could die would cause distress. 20. If not for Defendants' failure to safely prepare and serve fugu, Plaintiff, HOMER SIMPSON, would not have been rushed to the Springfield Hospital via ambulance and Plaintiff, MARGE SIMPSON, would not have been told that her husband had twenty-two hours to live, causing foreseeable distress and harm. WHEREFORE, Plaintiff, HOMER SIMPSON, and MARGE SIMPSON demand judgment against Defendants, HAPPY SUMO, INC., JIRO ONO, AKIRA SHUH, and JUBI SOUS, for all economic and non-economic damages to which they are entitled, the cost of this action, and general relief.4:47 PM Wed Feb 28 100% mycourses.spcollege.edu 1 of 4 IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIRCUIT CIVIL NO. HOMER SIMPSON & MARGE SIMPSON, Plaintiffs, V. HAPPY SUMO, INC., JIRO ONO, AKIRA SHUH, & JUBI SOUS. Defendants. PLAINTIFFS' COMPLAINT Plaintiffs, HOMER SIMPSON, and MARGE SIMPSON sue Defendants, HAPPY SUMO, INC., a Florida corporation, JIRO ONO, an individual, AKIRA SHUH, an individual, and JUBI SOUS, an individual, and hereby allege: COUNT 1 - NEGLIGENCE4:48 PM Wed Feb 28 100% mycourses.spcollege.edu PLAINTIFFS' COMPLAINT 1 of 4 Plaintiffs, HOMER SIMPSON, and MARGE SIMPSON sue Defendants, HAPPY SUMO, INC., a Florida corporation, JIRO ONO, an individual, AKIRA SHUH, an individual, and JUBI SOUS, an individual, and hereby allege: COUNT 1 - NEGLIGENCE 1. Pursuant to F.S. $ 26.012(2)(a), this court has jurisdiction over civil matters that exceed the value of $30,000. 2. This is an action for damages which exceed the sum of $30,000. 3. At all times material hereto, the Plaintiffs, HOMER SIMPSON, and MARGE SIMPSON, a married couple, were residents of Pinellas County, Florida. 4. Defendant, HAPPY SUMO, INC., was and is a for-profit corporation incorporated in Florida with its principal place of business located in Pinellas County, Florida. 5. At all times material hereto, Defendants, JIRO ONO, AKIRA SHUH, and JUBI SOUS were residents of Pinellas County, Florida.4:48 PM Wed Feb 28 100% mycourses.spcollege.edu 1 of 4 COUNT 1 - NEGLIGENCE 1. Pursuant to F.S. $ 26.012(2)(a), this court has jurisdiction over civil matters that exceed the value of $30,000. 2. This is an action for damages which exceed the sum of $30,000. 3. At all times material hereto, the Plaintiffs, HOMER SIMPSON, and MARGE SIMPSON, a married couple, were residents of Pinellas County, Florida. 4. Defendant, HAPPY SUMO, INC., was and is a for-profit corporation incorporated in Florida with its principal place of business located in Pinellas County, Florida. 5. At all times material hereto, Defendants, JIRO ONO, AKIRA SHUH, and JUBI SOUS were residents of Pinellas County, Florida. 6. On or about January 1, 2021, the Plaintiffs, HOMER SIMPSON, and MARGE4:48 PM Wed Feb 28 *@ 100% mycourses.spcollege.edu 2 of 4 SIMPSON were patrons at Defendant, HAPPY SUMO, INC.'s, restaurant. 7. On or about January 1, 2021, the Defendants', JIRO ONO, AKIRA SHUH, and JUBI SOUS, were employees and were acting in the course and scope of their employment at Defendant, HAPPY SUMO, INC.'s restaurant. 8. On or about January 1, 2021, Plaintiff, HOMER SIMPSON, ordered fugu, a dish containing puffer fish at Defendant, HAPPY SUMO, INC.'s restaurant. 9. Defendants knew or should have known that if not prepared properly, fugu (containing puffer fish) can be toxic to humans upon consumption. 10. Defendants entrusted the preparation of Plaintiff, HOMER SIMPSON's order of fugu to the restaurant's sous chef, JUBI SOUS, with or without the permission and consent of Defendant, JIRO ONO, the master chef of Defendant, HAPPY SUMO, INC. 1 1. Defendants served Plaintiff, HOMER SIMPSON, the fugu prepared by the restaurant's sous chef and Defendant, JUBI SOUS. 12. Upon consumption of the fugu, Plaintiff, HOMER SIMPSON, was informed by
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