Scenario:

The potential client, Kenny Collects, told the intake staff that he was shopping at Pat's Pets, a pet store located in a strip mall just outside of downtown Capital City. Mr. Collects states that he went there for an adoption event sponsored by the local animal shelter, hoping to adopt a new cat or kitten.Mr. Collects told someone at the store that he was there to see the cats and was directed to a closed door that opened to a room filled with a large number of cats available for adoption.Disappointed to find there were no kittens available, Mr. Collects started playing with a number of adult cats to see if any had a personality suitable to him. He found an unusual-looking cat in a corner, hiding, and felt drawn to it.It seemed shy and crawled under a low bench. Now feeling sorry for the cat, he leaned his face down to make sure it was okay. The cat immediately leapt from the hiding place and violently attacked Mr. Collects' face, scratching his eye, nose, mouth, and cheeks. The wounds were significant, and our potential client's wounds became infected, causing permanent scarring and partial vision loss in one eye.

Mr. Collects would like to sue Pat's Pets for negligence in not ensuring a safe environment for the adoption event.

The client meeting went well, and the firm has decided to take on the client and file the lawsuit on their behalf of against Pat's Pets. The firm decided not to name the animal shelter at this time, but proceeded only against the pet store.

Your research demonstrates that Pat's Pets is located within the city limits of Indiana capital. The adoption event your client attended was advertised on Pat's Pets Facebook page, and the announcement stated that all the pets available for adoption had been medically examined and determined ready for adoption, they had all been fixed or neutered, and received all appropriate shots and vaccinations. Your client saw this announcement and relied on it to adopt a cat from Pat's Pets.

Your client has previously owned numerous cats but is not an expert on veterinary medicine or cats. Your client reports that his physician has advised him that he currently has a 40% loss of vision in the left eye, which is likely to be long-lasting or permanent. The scarring on the client's face is chelated, obvious, and permanent. Aside from the scars, there is no long-term damage to the client's mouth.

The client has incurred medical bills of over $36,000 so far, with additional expenses likely should the client need eye surgery in the future. The client missed approximately four days of work at the time of the initial injury and another six half-days for follow-up medical care. Your client works as a tax accountant and earns a salary of $48,000 yearly. He has medical insurance, which has paid most of the bills.

You have been assigned to a Complaint using the Rules of Civil Procedure for Indiana for signature by Attorney Files. The Complaint must include the following:

1. Jurisdictional allegations.
2. Factual allegations that support all causes of action.
3. All the facts necessary to allege the elements of a negligent tort.
4. Wherefore clause and demand for damages.

The Complaint must contain the proper caption and identification of the parties and must be drafted in accordance with the rules and laws of Indiana.

Directions

Prepare the Complaint pursuant to the rules and law of Indiana. It is permissible for you to utilize forms in preparation of these pleadings and discovery demands. However, you must provide the citation(s) pursuant to The Bluebook for the source of your forms.