PA106 Unit 4 Assignment part 2 (1).docx - IN THE CIRCUIT COURT FOR PORTAGE COUNTY INDIANA TOM SMITH Plaintiff vs LA GRANDE FROMAGE LLC LA FROMAGE

PA106 Unit 4 Assignment part 2 (1).docx - IN THE CIRCUIT...

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IN THE CIRCUIT COURT FOR PORTAGE COUNTY, INDIANA. TOM SMITH, Plaintiff. vs. JURY DEMAND LA GRANDE FROMAGE LLC File No. 1234 LA FROMAGE., Defendant. COMPLAINT NEGLIGENCE Now comes Plaintiff, Tom Smith by his attorneys Wagner and Evans LLP complaining of the Defendant, La Grande Fromage LLC here and after refferred to as Defendant states as follows… 1. On and prior to the date of the incident Plaintiff, Tom Smith was a resident in the city of Portage, county of Porter, state of Indiana. 2. At all times material to this incident the Defendant an Indiana limited liability company was doing business in the state of Indiana. 3. Then on July 1 st , 2015, the Defendant owned and was doing business as La Grande Fromage at 444 Ridge Rd. Portage, Indiana 46368. ) ) ) ) ) ) ) ) ) )
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4. That on July 1 st , 2015 the Plaintiff, Tom Smith was a patron and/or invitee lawfully on the premises of La Grande Fromage. 5. The Defendant owes a duty to exercise reasonable care for Plaintiff’s safety.
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