Piggly Wiggly

Complaint on behalf of client

Sammy Hoagge plaintiff

July 3, 2012

IN THE CIRCUIT COURT OF THE

FIFTEENTH JUDICIAL CIRCUIT, IN

AND FOR PAM BEACH COUNTY,

FLORIDA, CIVIL DIVISION

CASE NO. 50 2010 CA 027288XXXX

MB AF

SAMMY HOAGGE, )

)

Plaintiff, )

)

vs. )

)

PIGGLY WIGGLY, LLC )

)

Defendant, )

-------------------------------------------------

)

-------------------------------------------------

-------------------------------------------------

COMPLAINT

Plaintiff, SAMMY HOAGGE, by and through his attorney, sues Defendant, PIGGLY WIGGLY, LLC, a FLORIDA COMPANY and alleges the following:

JURISDICTIONAL ALLEGATIONS

1. Plaintiff, SAMMY HOAGGE, was and is a resident of Palm Beach County, Florida and is otherwise there of his own free will.

2. PIGGLY WIGGLY, LLC, a FLORIDA COMPANY is a resident of Palm Beach County, Florida.

3. That this is an action for damages which exceed $15, 0000.00.

4. That all times hereto PIGGLY WIGGLY, LLC, a FLORIDA COMPANY has been a Florida company conducting business in Palm Beach county.

5. On June 1, 1995, Sammy Hoagge was injured in a meat department at a Lindy’s supermarket in West Palm Beach, Florida by defendant PIGGLY WIGGLY, LLC, a FLORIDA COMPANY’s meat slicer in which Plaintiff suffered serious and permanent injuries due to missing guard displaying “Caution! For Operation Guards Down.”

6. The missing guard displaying “Caution! For Operation Guards Down” caused Plaintiff to lose his left arm.

COUNT I

STRICT LIABILITY-DEFECTIVE WARNINGS

7. Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 6 of this Complaint.

8. Defendant PIGGLY WIGGLY, LLC, a FLORIDA...