Filing # 105501335 E-Filed 03/26/2020 04:18:05 PM 

IN THE CIRCUIT COURT OF THE 

11TH JUDICIAL CIRCUIT IN AND FOR 

MIAMI-DADE COUNTY, FLORIDA 

CASE NO: 2020-007206-CA-01 

Clarence Lawrence, 

Plaintiff, 

V. 

Target Corporation, 

a Foreign Corporation, 

Defendant. 

COMPLAINT FOR DAMAGES 

AND DEMAND FOR JURY TRIAL 

Comes Now, the Plaintiff, Clarence Lawrence, by and through the undersigned counsel, 

sues the Defendant, Target Corporation, a Foreign Corporation, and states the following: 

GENERAL ALLEGATIONS 

This is an action for damages in excess of the minimum jurisdictional limits of this 

Court, to wit, Fifteen Thousand ($15,000.00) Dollars, exclusive of interest and costs. 

2. Venue is proper in the 11 thJudicial Circuit in and for Miami-Dade County, Florida 

because the alleged tortuous conduct occurred in Miami-Dade County, Florida. 

3. At all times material, the Plaintiff, Clarence Lawrence is and was a resident of 

Miami-Dade County, Florida, over the age of eighteen (18) years and otherwise sui fur/s. 

4. At all times material herein, the Defendant, Target Corporation (hereinafter 

"Target"), is a Foreign Corporation, authorized to do business and doing business in the State of 

Florida. 

5. At all times material, Target owned, operated, controlled, rented, leased, 

maintained, and/or inspected Store #1075 located at 20500 SW. 112thAvenue, Miami, Florida 

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EXHIBIT A

Case 1:20-cv-22658-JEM Document 1-2 Entered on FLSD Docket 06/26/2020 Page 1 of 5
33189 (hereinafter "Premises"), where this action accrued. 

6. On or about July 27, 2017, the Plaintiff, Clarence Lawrence, was a business 

invitee on the Premises owned, leased, controlled, rented, inspected, and/or maintained by 

Target. 

7. On said day, the Plaintiff, Clarence Lawrence, was at the above mentioned 

Premises located on said Premises when he slipped and fell on a liquid on the floor which had 

been allowed to accumulate and turn into a puddle. 

8. The Plaintiff, Clarence Lawrence, has sustained foreseeable serious personal 

injuries and damages as more fully described hereinafter. 

COUNT I - NEGLIGENCE 

The Plaintiff adopts, reavers and realleges every allegation contained in the General 

Allegations paragraphs 1 through 8 of this Complaint as if set forth herein and further allege: 

9. At all times material, the Defendant, Target owned, leased, rented, and/or sold 

the Premises, wherein the Defendant, Target, personally, and/or by and through its agents, 

servants and/or employees operated, controlled, maintained, and/or conducted business. 

10. At all times material, the Plaintiff, Clarence Lawrence, was a business invitee 

onto the Defendant's, Target, premises, thus lawfully on the Premises. 

11. At all times material hereto, Defendant, Target, was responsible for the 

maintenance, safety, safekeeping and/or warning of dangers of the aforementioned Premises. 

12. On or about July 27, 2017, the Plaintiff, Clarence Lawrence, while on 

Target's Premises, was caused to slip and fall on a liquid on the floor which had been allowed to 

accumulate and turn into a puddle. 

13. The improperly maintained area in the Defendant's store created an unreasonable 

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and dangerous condition which the Plaintiff, Clarence Lawrence, was exposed to. 

14. That the Defendant, Target, its agents, servants and/or employees, owed the 

Plaintiff a duty to use reasonable care in the care, safekeeping, maintenance and control of its 

property, and to warn the Plaintiff of any hazards, which this Defendant knew or should have 

1 known about and which were not as equally obvious to the Plaintiff, Clarence Lawrence. 

15. That at said time and place, the Defendant, Target, its agents and/or employees 

were negligent and otherwise fell below acceptable standards of care including, but not limited 

to, the following: 

a) Caused or allowed a dangerous and defective condition, causing the 

Plaintiff to be exposed to the dangerous defective area on said Premises, 

which caused the Plaintiff, Clarence Lawrence, serious bodily injuries; 

b) Defendant negligently and carelessly failed to exercise due and reasonable 

care to monitor and inspect the subject defective and improperly 

maintained area, when Defendant knew or in the exercise of reasonable 

care should have known that the subject defective and improperly 

maintained area, and/or the area presented an unreasonable risk of harm to 

members of the public, visitors, and/or invitee and anyone traversing the 

subject area of the Defendant's Premise including the Plaintiff; Clarence 

Lawrence; 

c) Defendant negligently and carelessly failed to place cones, warning signs, 

or any other warning devices to secure the subject area so that it would not 

be exposed to members of the public, visitors, employees and/or invitees 

such as the Plaintiff, Clarence Lawrence, thus preventing Plaintiff from 

being injured by the aforementioned dangerous and defective condition on 

the Defendant's Premise; 

d) Defendant knew or in the exercise of reasonable care should have known 

of the above described dangerous condition, or in the alternative such 

dangerous and defective condition had existed for a length of time for 

which reasonable warning signs would have disclosed same; 

e) Defendant negligently exposed Plaintiff, Clarence Lawrence, to a 

foreseeable and unreasonable risk of harm and bodily injury; 

Defendant negligently failed to become adequately apprized of the extent 

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of the dangerous condition of the area and to take reasonable preventative 

action; 

g) Defendant failed to correct or adequately correct the unreasonably 

dangerous condition of the area on the Defendant's Premise, when said 

condition was either known to Defendant or had existed for a sufficient 

length of time such that the Defendant should have known of the same had 

Defendant exercised reasonable care; and/or 

h) Defendant was otherwise negligent in the inspection and/or maintenance 

and by failing to warn of the dangerous conditions of the subject common 

area of the Defendant's Premise; 

All of the above acts thereby breaching the duty of care to the Plaintiff. 

16. As a direct, proximate and foreseeable result of the negligence of the Defendant, 

Target, on or about July 27, 2017, the Plaintiff, Clarence Lawrence, sustained injuries which 

were caused and activated by the accident herein sued upon, and the Plaintiff is suffering the 

following damages which exist and will continue into the future: 

a. Bodily injury; 

b. Pain and suffering; 

c. Disability; 

d. Physical Impairment/ Permanent Injuries; 

e. Aggravation of pre-existing condition; 

f. Mental Anguish; 

g. Medical bills and expenses, both in the past and in the future; 

and/or 

j. Any and all other damages allowed by law. 

17. Plaintiff has suffered such losses and damages in the past and will continue to 

suffer same in the future. 

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WHEREFORE, the Plaintiff, Clarence Lawrence, demands judgment against the 

Defendant, Target Corporation, for compensatory damages, in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00) together with costs, interest, and any other relief that this Court 

may deem just and proper. 

DEMAND FOR JURY TRIAL 

The Plaintiff, Clarence Lawrence, further demands a trial by jury of all issues triable as 

a right by Jury. 

Respectfully Submitted, 

Dated: March 26, 2020. 

/s/ Carlos A. Velasquez 

Carlos A. Velasquez, Esq. 

Florida Bar No.: 755982 

CVelasouezaVDATrialLawyers.com Alejandro Larrazabal, Esq. 

Florida Bar No.: 102708 

A Larrazabalri4VDATrial Lawyers.com Velasquez Dolan Arias, P.A. 

101 N. Pines Island Road, Suite 201 

Plantation, Florida 33324 

Telephone: (954) 382-0533 

Facsimile : (954) 382-0585 

Attorney for Plaintiff 

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