Plaintiff, LENORA ALVARADO, by her attorneys, SHULMAN & HILL, PLLC, as and for her Verified Complaint against the defendant A METROMAIN INC. d/b/a A METRO MAINTENANCE respectfully sets forth and alleges as follows upon information and belief:

On April 19, 2023, and for some time prior thereto, the defendant, its officers, agents, servants and/or employees suffered, caused, permitted, and allowed the Premises to be, become, and remain in a defective, hazardous, and dangerous condition so as to constitute a menace, nuisance, hazard and trap to the life and limb of persons lawfully upon the Premises, and in particular the plaintiff LENORA ALVARADO, all of which the defendants, their officers, agents, servants, and/or employees had notice of, or in the exercise of reasonable care and caution, should have had notice thereof, and in that under all of the facts and circumstances, including acts of commission and omission, the defendants were careless, reckless and negligent in the Premises.

As a result of the aforesaid occurrence, the plaintiff LENORA ALVARADO sustained severe, serious, and permanent personal injuries and damages.

The aforesaid incident and resulting injuries to the plaintiff LENORA ALVARADO were caused solely and wholly by reason of the negligence, recklessness, and carelessness of the defendants, their officers, servants, agents, and/or employees.

By reason of the aforesaid occurrence, the plaintiff LENORA ALVARADO, sustained serious, severe, and permanent personal injuries and damages, and was rendered sick, sore, lame and disabled, and upon information and belief was permanently injured and so remains, and was caused to suffer and will continue to suffer great physical pain and mental anguish, and has been compelled to incur divers obligations in an effort to cure herself of her said injuries and upon information and belief will be compelled to incur further such obligations for an extensive time in the future, and was forced to remain away from her usual and customary duties and activities for an extended period of time, all to his damage in a sum which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction over this action.