1. STATE OF MICHIGAN
IN THECIRCUIT COURT FOR THE COUNTY OF OAKLAND
Lynn Cartman,
Plaintiff, Case no.XXXXX
Hon. JESSICA A. FALLS
v
South Park Market
Defendant.
____________________________________________________________________________________________/
FALLS, PLLC (P307330) FALLSBRIGHT, PLLC (P
Beatrice L. Falls Bettie Albright
521 Modern World Futuristic Lane
Suite 32016 Suite 2024
Kalamazoo, MI 49009 Kalamazoo, MI 49009
(269)929-7274 (269)929-7274 #3
PLAINTIFF’S CASE EVALUATION SUMMARY
APRIL 24, 2015 approximately 5:30 P.M.
Plaintiff Lynn Cartman through her counsel, FALLS, PLLC, states the following for her case
evaluation:
INTRODUCTION
This case arises from Plaintiff’s alleged slip and fall accident at a shopping market in Auburn
Hills. Plaintiff’s intentions for having visited the market that day, was to cash her check at the
customer service desk. As Plaintiff was entering the store, she walked down the main concourse
toward the customer desk. As Plaintiff walked closer to the desk, Plaintiff slipped and fell in a
puddle of blue solution on the tile floor. The measurement of the puddle of blue solution seemed to
cover many small broken up spaces. Plaintiff tried to resolve the matter directly with South Park
Management, which refused to communicate with Plaintiff. Ultimately, as a result, on April 24,
2. 2015, Plaintiff, filed a claims action in circuit court alleging that South Park Market was negligent by
not exercising the proper care of the tile floor where Plaintiff sustained debilitating injuries, in turn,
which cause injuries to Plaintiff’s neck and lower back causing her to miss a great deal of work and
drastically limit her once active lifestyle.
FACTS
On March 24, 2015, Plaintiff enteredthe premisesof SouthParkMarketin Auburn Hills to cash her
check at the customer service desk. As Plaintiff walked the main concourse toward the service desk,
Plaintiff slipped and fell, on the tile floor covered by puddles of blue solution, which caused Plaintiff
to suffer injuries in her lower back and neck. South Park Market owes a duty and responsibility to
Plaintiff by exercising reasonable care to its patrons.
PLAINTIFF SUFFERING AN INJURY AT THE NEGLIGENCE OF AN OWNER
PLAINTIFF’S SUSTAINED INJURIES FROM THE NEGLIGENCE OF A PREMISES OWNER
IS A CLASSIC CASE OF RES ISPA LO QUITOR. This is a classic case of res ipsa lo quitor which
entitles a plaintiff to permissible inference of negligence from circumstantial evidence. The physical,
emotional, and mental damages suffered by Plaintiff are not of sum certain. Fees associated with
injuries of this capacity can be considered incalculable. Hospital fees, therapy fees, missed days from
work, are few of many setbacks that escalate the astronomical costs associated with having sustained
such traumatic injuries. Property owners owe the highest degree of care to invitees to make sure they
are safe from dangers on their property. Under this standard, a property owner not only has a duty to
repair and correct known dangers, but he also has a duty to reasonably inspect for, discover, and
correct unknown hazards in those areas of a premise in which an invitee might have access. The law
defines reasonable as what a person of ordinary intelligence and judgment would do under the same
circumstances if a premises liability case goes to trial. It is left up to a jury to decide what is
reasonable under those circumstances.
3. It would be advantageous to have a jury decide the capacity and extent of a fair and meaningful value
of this case.
CUSTOMER ACCIDENT INJURY
Lynn Cartman D.O.B: May 3, 1972
1234 Main St. City:
(269) 345-9099: Obamacare Occupation:
Date/Time of Incident: Employer:
Details of bodily injury: Incident Type: