Академический Документы
Профессиональный Документы
Культура Документы
This is an action for wrongful death damages in excess of Five Million Dollars
At all times material to this action, the decedent EXPAVIOUS TYRELL TAYLOR
3.
The Defendant PUSHING DAIZIES, INC. at all times material hereto, was and is
a Florida not-for-profit corporation licensed and doing business in Lee County Florida and at all
times material hereto was the sponsor and organizer of the ZombiCon - Fallout: 1985.
4.
INC., at all times material hereto was a Florida corporation licensed and doing business in Lee
County, Florida.
5.
At all times material hereto, the decedent EXPAVIOUS TYRELL TAYLOR was a
business invitee at ZombiCon and had a reasonable expectation that the Defendants would
provide for his safety and the safety of others attending the event.
7.
TAYLORS maternal grandmother and is the prospective personal representative of his Estate.
8.
At all times material hereto, the Defendants owed a duty to the public, including
EXPAVIOUS TYRELL TAYLOR to exercise reasonable and ordinary care to keep and maintain
the ZombiCon event in a condition reasonably safe for the public and its patrons. In particular,
the Defendants had a duty to take such precautions as were reasonably necessary to protect its
invitees, including the decedent, from criminal attacks which were reasonable foreseeable.
9.
The Defendants knew, or in exercise of reasonable care should have known, that
the premises where the ZombiCon was occurring was a high crime area, and that there had been
numerous criminal acts and attacks perpetrated on the public in this area and that such criminal
acts and attacks were reasonably likely to be perpetrated on business invitees of the Defendants
during ZombiCon unless the Defendants took steps to provide proper security for such
individuals.
COUNT INEGLIGENCE OF PUSHING DAIZIES, INC.
Plaintiff realleges all allegations in paragraphs 1 through 9 above as if set forth fully
herein and further states:
10.
The Defendant PUSHING DAIZIES, INC. was negligent and breeched its duty of
reasonable care for the safety and protection of the public in general and the decedent in
particular in one or more of the following ways:
A.
ZombiCon event, which occurred in Fort Myers, Florida, October 17, 2015.
B.
C.
D.
Failing to take additional security measures after being put on notice that
20,000.
Negligently failing to insure that the security guards and other personnel
hired for event security were properly trained to do so, so that they could protect the invitees of
the Defendants to the event, including the decedent.
F.
measures and security procedures necessary to protect the decedent and others at the event.
The Defendant SFSI was negligent and breeched its duty of reasonable care for
the safety and protection of the public in general and the decedent in particular in one or more of
the following ways:
A.
ZombiCon event, which occurred in Fort Myers, Florida, October 17, 2015.
B.
C.
D.
Failing to take additional security measures after being put on notice that
20,000.
Negligently failing to insure that the security guards and other personnel
hired for event security were properly trained to do so, so that they could protect the invitees of
the Defendant to the event, including the decedent.
F.
measures and security procedures necessary to protect the decedent and others at the event.
DAMAGES
12.
Defendants, the decedent was shot and killed while on the premises of ZombiCon by an as-yet
unknown assailant.
13.
Defendants, the Estate of EXPAVIOUS TYRELL TAYLOR has suffered the following damages:
A.
B.
C.
WHEREFORE, the Plaintiff demands judgment against the Defendants for all damages
recoverable under the laws of the state of Florida in the amount greater than Five Million Dollars
($5,000,000).
DEMAND FOR JURY TRIAL
The Plaintiff herein demands a trial by jury on all issues so triable by law.