You represent the Plaintiff in this case, Chris Moodeling. The plaintiff has filed a lawsuit in the below fact case scenario, What would you put in an "opening statement" as the plaintiff for the below case.

Case of the Hairless Cat

Bobbi Swell always wanted to own her own pet store, so 8 years ago she

opened Bald and Beautiful Pet Store. The store is located in Tampa,

Florida and specializes in the breeding and sale of hairless cats. Over the

last 3 years, business has been booming as she expanded to internet

sales. In addition to selling her hairless friends, she also sells hypo-

allergenic products to care for them. Obviously, her primary customers are

individuals who are allergic to pet dander and hair.

In August 2019 Bobbi created a product to reduce pet dander which she

markets via her pet store and sold online. The product, Cair (instead of

Nair) was selling like hotcakes as it is all natural and guaranteed to remove

your pet's nasty dander.

Chris Moodeling is a hair model for Head and Shoulders shampoo.

Ironically he has an allergy to pet hair and dander so he purchased his

hairless cat, Mike, from Bobbi last year while traveling through Tampa.

In

January 2020 he began sneezing and coughing around the cat so he

ordered a bottle of Cair, online, from Bald and Beautiful at a cost of $42.00

plus shipping. He began using Cair on or about January 21st and

immediately noticed a reduction in his sneezing and coughing, however,

about 2 weeks later he began to notice his hair thinning. This of course is

not good for a hair model and he's only 35.

Chris immediately looked at the Cair packaging and did not see any

warning signs about its use, nor did he see any ingredients that might

cause hair loss. He then went to his doctor who told him it appeared to be

an allergic reaction, but by this time a week had passed and he had

multiple bald spots on his scalp. As a result of the hair loss Chris lost his

contract with Head and Shoulders and fell into a pit of despair.

Also, Chris was required to use only Head and Shoulders shampoo and

hair products and was religious about doing so.

Coincidentally, Chris

received a new shipment of shampoo and conditioner from Head and

Shoulders around that same time he received his pet dander shampoo.

Not knowing what to do next and fearful he would lose not only his job, but

his home and of course be unable to care for Mike, he contacted an

attorney. The attorney advised him to file a lawsuit against Bobbi after

having Cair analyzed by a chemist.

The chemist, Ike Ranium, determined that the ingredients include garlic,

aloe, turmeric, mint, lavender, orange peel, argon oil and trace elements of

calcium hydroxide and sodium hydroxide, neither of which are listed

ingredients on the bottle. The last two ingredients are known to cause hair

loss and in fact are the main ingredients in the product Nair. The testing

was done specifically on the bottle of Cair Chris purchased.

TNT Manufacturing, Inc., the company Bobbi uses to manufacture her

product is located in Lawton, Oklahoma. TNT not only blends the

ingredients for Bobbi's product, but for many other companies as well,

including Nair.

Chris was earning $5,000.00 a photo shoot averaging 3-4 shoots a month.

He continues to reside in St. Petersburg, Florida, and has been a resident

of Pinellas County for over 20 years.

It's a year later and Chris is now

working as a barista at Starbucks simply to make ends meet.

He had to sell his Mazzarati and downsize to a small 1

bedroom garage

apartment.

It appears the hair loss is permanent.