In the circuit court of

Mecklenburg county state court

in Charlotte, NC

Sidney Kester /Case no ..............................

Plaintiff

vs

Monroe's Grocery Store

Defendant

Explanation:

In the circuit court of

Mecklenburg county state court

in Charlotte, NC

Sidney Kester /Case no ..............................

Plaintiff

vs

Monroe's Grocery Store

Defendant

COMPLAINT

Sidney Kester( the " Plaintiff) hereby sues Monroe Grocery Store( the "Defendant")and alleges as follows;

INTRODUCTION

The Plaintiff is a male , who is a resident of State of North Carolina , Charlotte, NC

The Defendant is an company incorporated and carrying on business in the State of North Carolina , located in Charlotte, NC.

About two months ago the Plaintiff was shopping in the produce department store of the Defendant when he slipped on some produce on the floor in the Defendant store and fractured his knee.

On that day, the produce manager an employee of the Defendant store was restocking tomato bins and many crates were on the aisle.

The produce manager, restocked the tomato bins carelessly or negligently, that several tomatoes fell from a crate to the floor, therefore causing the floor to be slippery.

The produce manager and the Defendant failed to take reasonable steps to ensure the floor was dry and safe to walk on by the customers shopping in the store .

JURISDICTION

7 .This Court has jurisdiction because there is no basis for federal subject-matter jurisdiction.

8.The Plaintiff therefore seeks Special and General damages for injury and loss occasioned on him by the Defendant.

PARTICULARS OF SPECIAL DAMAGE

a)Medical bills amounting to $25,000 out of pocket.

PARTICULARS OF GENERAL DAMAGES

a) Loss of earnings due to being out of work for several weeks.

b) Pain and suffering.

c) Inability to return to his lifestyle due to the use a cane for the rest of his life.

Dated ....................

Submitted by;-

Sidney Kester

State of North Carolina , Charlotte, NC

To be served upon;-

Monroe's Grocery Store

State of North Carolina , Charlotte,

Draft an answer to the complaint above.Are there any other Rule 12 responses which might be appropriate?Identify the other responses that may be appropriate and the basis for such responses.