IN THE CIRCUIT COURT, FOURTH

JUDICIAL CIRCUIT, IN AND FOR

DUVAL COUNTY, FLORIDA
Peter Pan II,

CASE NO.:

Plaintiff,
vs.

DIVISION:

AMC ENTERTAINMENT HOLDINGS, Inc.,

Defendant.
/
COMPLAINT
Plaintiff, Peter Pan II, sues Defendant, AMC ENTERTAINMENT HOLDINGS, INC., and
alleges:
This is an action for damages that exceeds $15,000.00 exclusive of costs and

1.

attorneys fees.
That at all times material hereto; Plaintiff, Peter Pan, is a resident of Jacksonville,

2.

Duval County, Florida.

3.

Defendant is a corporation doing business in the State of Florida and elsewhere.

4.

On or about the 22nd day of September, 2016, the Defendant owned and operated
AMC Regency 24 movie theater at 9451 Regency Square Boulevard,
Jacksonville, Florida 32225 (Duval County).

5.

On the said date, Plaintiff was an invitee at the theater as he was there to watch a
movie.

6.

On the said date, the Defendant negligently caused and/or allowed a foreign
substance to exist on the floor in a business establishment failing to produce a safe,
suitable, and fit environment for invitees to walk thereon.

7.

Defendant had actual and/or constructive knowledge of the dangerous condition

and should have taken action to remedy such. The dangerous condition existed for
such a length of time that, in the exercise of ordinary care, the Defendant should

have known about the condition and/or the condition occurred with regularity and
was therefore foreseeable.
8.

In consequence of the negligence and carelessness of the Defendant, the Plaintiff,

Peter Pan, suddenly slipped and fell.

9.

As a result, the Plaintiff experienced immediate bodily injury, resulting in

excruciating pain and suffering, disability, disfigurement, mental anguish, loss of
capacity for the enjoyment of life, expense of surgery and hospitalization, medical
treatment, loss physical ability to complete many daily activities, loss of ability to
work, and suffers pain in his left knee during his everyday activities. The Plaintiffs
physical ability to complete many daily activities has been greatly affected by this
incident. However, due to his constant pain and his unstable left knee, he continues
to fall occasionally due to his right knee giving way and he is unable to enjoy
walking or running. Prior to the incident, my client had no problems with walking,
running, sitting, standing for long periods of time, and any other forms of exercise.

10.

These stresses affect the Plaintiffs concentration at home and present work
environments. This incident has affected the Plaintiffs ability to complete duties at
home and has impacted his efforts of maintaining the lifestyle that he is accustomed
to prior to this horrible incident.

WHEREFORE, the Plaintiff demands judgment against the Defendant for damages and
demand trial by jury.

DATED this _____ day of January, 2016.

_____________________________
Sleeping Beauty, Esquire
Sleeping Beauty, P.A.
101 North Union Street, Suite 7
Jacksonville, FL 32202

T: 904-355-5555
F: 904-355-5556
Sleeping Beauty @justicesb.com
Florida Bar No.: 0123456
Attorney for Plaintiff