Drafting a complaint

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KESTER V. MONROE'S GROCERY STORE

Sidney Kester is a 65 year old computer operator. He routinely shops at Monroe's Grocery Store, which is very close to his home. Approximately two months ago, while shopping in the store, he slipped in the produce department and fractured his knee. Although he is recovering, he missed several weeks of work, and his doctors advise him that he will probably need to use a cane for the rest of his life.

Mr. Kester does not know what he slipped on, but he does recall noticing that the produce manager was in the process of restocking many of the bins and that crates filled several of the aisles. In one aisle in particular he recalls noticing that several tomatoes had fallen from a crate onto the floor. Mr. Kester was in front of the lettuce bin at the time of the fall.

Using this hypothetical case, draft a complaint on behalf of Mr. Kester against Monroe's Grocery Store.Be sure to include all the proper format requirements for drafting a complaint in court.Assume that Monroe's Grocery Store is incorporated in the State of North Carolina that is located in Charlotte, NC, and that there is no basis for federal subject-matter jurisdiction, and that you are filing in Mecklenburg county state court. Also assume that the medical bills resulting from the fall total $25,000 out of pocket.