This is for writing a legal complaint, if you CANNOT HELP, do not simply leave me with some bs like needed information, I am giving all that is given to me. If you cannot help, move on so someone can. I'm also explaining the gist of the cases.

These are my instructions:

Draft Complaint Based on Following Facts:

On March 12, 2017, our client, Phillip Bannery, was shopping at the Winn Pride Grocery store located at 2700 W. Granada Boulevard in Ormond Beach, Florida. The Winn Pride store is owned and operated by Winn Pride Store Systems, Inc. Winn Pride Store Systems, Inc. is a Florida Corporation based in East Palatka Florida. Phillip Bannery is a Florida resident and lives in Daytona Beach.

Bannery was walking down the produce aisle of the store when he slipped and fell on a slippery substance on the floor. Bannery could not identify the substance, but he thought it might be smashed grape residue. Due to the fall, Bannery suffered severe injuries. These injuries included contusions to Bannery's left leg, a fractured left wrist, soreness to his ribs, post-traumatic pain in his left shoulder, anxiety, and other injuries including soft tissue injuries. As a result of the fall and these injuries, Bannery incurred medical expenses, missed three (3) weeks of work, was deeply embarrassed and his overall health and vitality have been greatly impaired. Bannery estimates that his damages amount to $375,000. Bannery suspects that Winn Pride failed to maintain the store in a good and safe condition, and failed to properly inspect the shopping aisles in the store. Mr. Bannery wishes to file a civil complaint against Winn Pride seeking payment for his losses and damage.

Additional Facts:

You work at the firm of:

Cupick, Bogdanoff Grippa & Richardson

1200 W. International Speedway Boulevard

Daytona Beach, FL 32114

(386) 506-3202

FAX: (386) 505-1234

Your supervising attorney is:

John N. Bogdanoff (put your name in parenthesis for grading purposes)

Opposing Counsel:

Perry Mason

Huntley, Kirbridge & Dillon

165 Eaton Place

Winter Park, FL 32789

(407) 238-3855

Our Client:

Phillip Bannery

1200 West Pelican Drive

Daytona Beach, FL 32119

Formatting a Complaint:

• The Case Caption
• The Title of the Pleading
• A Short Introduction
• The Parties
• The Jurisdictional and Venue Allegations (What Gives Court the Authority to Hear the Case-Jurisdiction; and That the Chosen Courthouse is Correct-Venue)
• The Basis for the Complaint (Cause of Action-Legal Theory)
• The Damages Suffered
• The Request for Relief (Prayer for Relief)
• The Demand for a Jury Trial (if appropriate)
• The Date When the Complaint is Filed
• The Signature of the Attorney (Including Bar #, Address, Phone & Which Party the Attorney Represents)

Authorities:

• Winn-Dixie Stores, Inc. v. Marcotte, 553 So. 2d 213 (Fla. 5th DCA 1989)
• Owens v. Publix Supermarkets, Inc., 802 So. 2d 315 (Fla. 2001)
• Colon v. Outback Steakhouse of Florida, 721 So. 2d 769 (Fla. 3d DCA 1998)
• Williams v. Sears, Roebuck & Co., 866 So. 2d 122 (Fla. 4th DCA 2004)
• Pittman v. Volusia County, 380 So. 2d 1192 (Fla. 5th DCA 1980)
• Dampier v. Morgan Tire & Auto, LLC, 82 So. 3d 204 (Fla. 5th DCA 2012)
• Aaron v. Palatka Mall, LLC, 908 So. 2d 574 (Fla. 5th DCA 2005)
• Sinfort v. Food Lion, LLC, 908 So. 2d 521 (Fla. 5th DCA 2005)
• Delgado v. Laundromax, Inc., 65 So. 3d 1087 (Fla. 3d 2011)

• 768.0755, Fla. Stat. : 768.0755Premises liability for transitory foreign substances in a business establishment. (1)If a person slips and falls on a transitory foreign substance in a business establishment, the injured person must prove that the business establishment had actual or constructive knowledge of the dangerous condition and should have taken action to remedy it. Constructive knowledge may be proven by circumstantial evidence showing that: (a)The dangerous condition existed for such a length of time that, in the exercise of ordinary care, the business establishment should have known of the condition; or (b)The condition occurred with regularity and was therefore foreseeable. (2)This section does not affect any common-law duty of care owed by a person or entity in possession or control of a business premises.

These cases in authority mostly highlight how the plaintiff did not give enough evidence in a slip and fall and or negligence case.

my work so far. any insight would be helpful. AGAIN I AM DRAFTING A COMPLAINT.

Philip Bannery Plaintiff[s]. vs. Winn Pride Store Systems, Inc. Defendant[s]. ____________________________________/

Case No. ____________________

COMPLAINT

COMES NOW the PLAINTIFF, Philip Bannery, by and through his undersigned attorney, hereby files a Complaint for Negligence and Damages against the DEFENDANT, Winn Pride Store Systems, Inc.and alleges as follows:

1. THE PARTIES

1. That at all times material hereto, PLAINTIFF Phillip Bannery, is a resident of Daytona Beach, Florida, residing at 1200 West Pelican Drive, Daytona Beach, FL 32119.

2. That at all times material hereto, DEFENDANT Winn Pride Store Systems, Inc. ("Winn Pride"), is a Florida Corporation with its principal place of business located in East Palatka, Florida. Winn Pride operates the Winn Pride Grocery store located at 2700 W. Granada Boulevard, Ormond Beach, Florida.

1. JURISDICTION AND VENUE

3.This is in action for damages in excess of fifty thousand dollars ($50,000), exclusive of court fees and costs.

4.The venue is proper as the PLAINTIFF, Phillip Bannery, at the time of the incident, resided in Volusia County, Florida, where the incident and basis of this complaint took place.

III. CAUSE OF ACTION

5. On March 12, 2017, PLAINTIFF, Phillip Bannery, was a patron of the Winn Pride Grocery store at their Granada Boulevard location in Ormond Beach, Florida. While shopping at the store, the PLAINTIFF was walking down the produce aisle when he suddenly slipped and fell on a slippery substance present on the store's floor. PLAINTIFF was unable to identify the nature of the substance but suspected it might have been smashed grape residue.

6. As a result of the fall, the PLAINTIFF sustained severe injuries, including contusions to his left leg, a fractured left wrist, soreness to his ribs, post-traumatic pain in his left shoulder, anxiety, and other soft tissue injuries. These injuries have caused him significant pain and suffering.

7. In addition to the physical and emotional injuries, the PLAINTIFF incurred substantial medical expenses, missed three (3) weeks of work, and his overall health and vitality have been significantly impaired.

9. The PLAINTIFF estimates that his total damages amount to $375,000.

IV. COUNT 1- NEGLIGENCE

10. PLAINTIFF avers all the allegations in paragraphs 1 through 9 and incorporates them as though they were fully set forth herein.

11. PLAINTIFF was a business invitee on the premises of the Winn Pride Grocery store.

12. The DEFENDANT owed the PLANTIFF a duty to exercise ordinary care in maintaining the store premises and to keep the store aisles free from hazardous conditions.

13. Winn Pride breached its duty to BANNERY by failing to maintain the store in a good and safe condition, allowing the presence of a slippery substance on the floor.

14. WINN PRIDE further breached its duty by failing to properly inspect the shopping aisles to identify and address hazardous conditions.

15. Had WINN PRIDE exercised ordinary care, it would have prevented the hazardous condition that led to BANNERY's injuries.

16. WINN PRIDE's negligence was a direct and proximate cause of BANNERY's injuries, resulting in pain and suffering, disability, medical expenses, and loss of earnings.

17. BANNERY's injuries and losses are permanent or continuing in nature, and he will continue to suffer them in the future.