Wolters Kluwer 

PROCESS SERVER DELIVERY DETAILS 

Date: Fri, Jul 24, 2020 

Server Name: John Van Steekiste 

Location: Pompano Beach, FL 

Entity Served 

Agent Name 

TARGET CORPORATION 

CT CORPORATION SYSTEM 

Case Number 

_ . . 

Jurisdiction 

200000568CAAMXM 

FL 

II II II II III II 

Exhibit 2

Case 2:20-cv-14285-KMM Document 1-2 Entered on FLSD Docket 08/13/2020 Page 1 of 10
v. 

TARGET CORPORATION / if‘. 

Defendant. 

THE STATE OF FLORIDA 

f..7) 

To Each Sheriff of the State: 

YOU ARE COMMANDED to serve this Summons and a copy of the Complaint or Petition in 

this action on Defendant(s): 

Filing # 110643980 E-Filed 07/22/2020 04:00:55 PM 'ThZ2( 

Filing # 110548871 E-Filed 07/21/2020 12:21:41 PM 

IN THE CIRCUIT COURT OF THE 19Til JUDICIAL CIRCUIT, 

IN AND FOR MARTIN COUNTY, FLORIDA 

CASE NO.: 20000568CAAXMX 

HILDA PAZ, CIVIL ACTION SUMMONS 

Plaintiff, (Corporate Service) ft 1 

'?O 

TARGET CORPORATION 

CT CORPORATION SYSTEM, REGISTERED AGENT 

1200 S. PINE ISLAND ROAD 

PLANTATION, FL 33324 

Each defendant is required to serve written defenses to the complaint or petition on TIRADOLUCIANO & TIRADO, P.A., Plaintiffs attorney, whose address .is 2655 LeJeunc Rd., Suite 

1109, Coral Gables, FL 33134, within 20 days after service of this summons on that defendant, 

exclusive of the day of service, and to tile the original of the defenses with the clerk of this court 

either before service on Plaintiff's attorney or immediately thereafter. If a defendant fails to do 

so, a default will be entered against that defendant for the relief demanded in the complaint or 

petition. 

Dated on: 

CAROLYN T1MMANN 

CLERK OF THE RC 1 COURT & COMPTROLLER 

Electronically Filed Martin 07/21/2020 12:21 PM 

r7I2R , 2020. 

Case 2:20-cv-14285-KMM Document 1-2 Entered on FLSD Docket 08/13/2020 Page 2 of 10
Florida Rules of Judicial Administration Rule 2.540 Notices to Persons With 

Disabilities 

If you are a person with a disability who needs any accommodation in 

order to participate in this proceeding, you are entitled, at no cost to you, to 

the provision of certain assistance. Please contact Court Administration, 

250 NW Country Club Drive, Suite 217, Port St. Lucie, FL 34986, (772) 

807-4370 at least 7 days before your scheduled court appearance, or 

immediately upon receiving this notification if the time before the 

scheduled appearance is less than 7 days; if you are hearing or voice 

impaired, call 711. 

SPANISH: Si usted es una persona discapacitada que necesita algtin tipo de 

adecuaci6n para poder participar de este procedimiento, usted tiene 

derecho a que se le ayude hasta cierto punto y sin costo alguno. Por favor 

comuniquese con Court Administration, 250 NW Country Club Drive, 

Suite 217, Port St. Lucie, Fl. 34986, (772) 807-4370, al menos 7 dias antes de 

su fecha de comparecencia o inmediatamente despite's de haber recibido 

esta notificacion si faltan menos de 7 dias para su cita en el tribunal. Si 

tiene discapacidad auditiva o de habla, flame al 711. 

KREYOL: Si ou se yon moun Id andikape epi ou bezwen nenpet 

akomodasyon pou ou ka patisipe nan pwose sa-a, ou gen dwa, san ou pa 

gen pou-ou peye anyen, pou yo ba-ou yon seri de asistans. Tanpri kontakte 

Administrasyon Tribunal-la, 250 NW Country Club Drive, Suite 217, Port 

St. Lucie FL 34986, (772) 807-4370 omwen 7 jou alavans jou ou gen pou-ou 

paret nan tribunal-la, ouswa imedyatman kote ou resevwa notifikasyon-an 

si ke II mwens ke 7 jou; si ou soud ouswa Ube, rele 711. 

Case 2:20-cv-14285-KMM Document 1-2 Entered on FLSD Docket 08/13/2020 Page 3 of 10
If you are a person seeking to enter the courthouse please be aware of the 

following requirements. 

Upon entry to the courthouse your temperature will be taken in a nonintrusive manner. Persons with temperatures over 100.4 degrees Fahrenheit 

will be denied entry into the courthouse. All persons entering the courthouse 

will be further screened by a questionnaire: 

1. Have you recently had close contact with a person with COVID-19? 

2. Have you been diagnosed with CO'VID-19, are you waiting for test 

results, or do you have a cough, fever, or shortness of breath, or 

other symptoms of COVID-19? 

3. Have you recently traveled from somewhere outside the United 

States or on a cruise ship? 

You will be required to wear a face covering. Please bring your own face 

covering if you have one.If you do not possess one, a disposable mask will be 

provided to you. All individuals shall observe social distancing within 

courthouses by maintaining the recommended minimum six-foot distance 

from other individuals. Frequently sanitize your hands while you are in the 

courthouse. 

Case 2:20-cv-14285-KMM Document 1-2 Entered on FLSD Docket 08/13/2020 Page 4 of 10
Filing # 110018073 E-Filed 07/09/2020 03:04:02 PM 

FORM 1.997. CIVIL COVER SHEET 

The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of 

pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the 

Clerk of Court for the purpose of reporting data pursuant to section 25.075, Florida Statutes. (See instructions 

for completion.) 

I. CASE STYLE 

IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT, 

IN AND FOR MARTIN COUNTY, FLORIDA 

Case No.: 

Judge: 

Hilda Paz 

Plaintiff 

vs. 

Target Corproation 

Defendant 

AMOUNT OF CLAIM 

Please indicate the estimated amount of the claim rounded to the nearest dollar $500,000 

TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the 

most descriptive label is a subcategory (is indented under a broader category), place an x on both the main 

category and subcategory lines. 

O Condominium 

*0 Contracts and indebtedness 

O Eminent domain 

O Auto negligence 

Z. Negligence — other 

O Business governance 

O Business torts 

O Environmental/Toxic tort 

O Third party indemnification 

O Construction defect 

O Mass tort 

O Negligent security 

O Nursing home negligence 

El Premises liability — commercial 

O Premises liability — residential 

O Products liability 

O Real Property/Mortgage foreclosure 

O Commercial foreclosure 

El Homestead residential foreclosure 

'Non-homestead 'residential toreclosure 

O Other real property actions 

O Professional malpractice 

O Malpractice — business 

O Malpractice — medical 

O Malpractice — other professional 

0 Other 

0. Antitrust/Trade Regulation 

O Business Transaction 

O Circuit Civil - Not Applicable 

O Constitutional challenge-statute or ordinance 

O Constitutional challenge-proposed amendment 

O Corporate Trusts 

O Discrimination-employment or other 

O Insurance claims 

O Intellectual property 

O Libel/Slander 

O Shareholder derivative action 

O Securities litigation 

O Trade secrets 

O Trust litigation 

0 County Civil 

O Small Claims up to $8,000 

O Civil 

O Replevins 

O Evictions 

O Other civil (non-monetary) - 

Case 2:20-cv-14285-KMM Document 1-2 Entered on FLSD Docket 08/13/2020 Page 5 of 10
COMPLEX BUSINESS COURT 

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the 

Administrative Order. Yes CI No 23 

IV. REMEDIES SOUGHT (check all that apply): 

Monetary; 

O Non-monetary declaratory or injunctive relief; 

O Punitive 

V. NUMBER OF CAUSES OF ACTION: 

(Specify) 

VI. IS THIS CASE A CLASS ACTION LAWSUIT? 

CI Yes 

N No 

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED? 

N No 

CI Yes — If "yes" list all related cases by name, case number and court: 

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT? 

O Yes 

ID No' 

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and 

that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425. 

Signature: s/ Alejandro Tirado-Luciano 

Attorney or party 

FL Bar No.: 70894 

(Bar number, if attorney) 

Alejandro Tirado-Luciano 

(Type or print name) 

Date: 07/09/2020 

Case 2:20-cv-14285-KMM Document 1-2 Entered on FLSD Docket 08/13/2020 Page 6 of 10
Filing # 110018073 E-Filed 07/09/2020 03:04:02 PM 

IN THE CIRCUIT COURT OF THE 19TH 

JUDICIAL CIRCUIT, IN AND FOR 

MARTIN COUNTY, FLORIDA. 

HILDA PAZ, 

CASE NO.: 

Plaintiff, 

vs. 

TARGET CORPORATION 

Defendant. 

COMPLAINT AND DEMAND FOR JURY TRIAL 

Plaintiff, HILDA PAZ ("Plaintiff"), by and through her undersigned counsel, sues 

Defendant, TARGET CORPORATION ("Defendant"), and alleges: 

1. This is an action for negligence. This action is within the jurisdiction of this Court 

and for damages in excess of Thirty Thousand and 00/100 Dollars ($30,000.00), exclusive of 

interest and costs. 

2 At all times material hereto, Plaintiff is and was a citizen of the State of Florida 

residing in Miami-Dade County, Florida. 

3. At all times material hereto, Defendant is and was a foreign, for-profit corporation 

authorized to do business, and does conduct business in Martin County, Florida. 

4. Venue is proper in Martin County pursuant to § 47.051 because the cause of action 

accrued in Martin County as the accident occurred there. 

5. On or about July 4, 2018, Plaintiff was a customer of the Defendant at its store 

located at 2650 NW Federal Hwy, Stuart, FL 34994 (the "Premises") 

Case 2:20-cv-14285-KMM Document 1-2 Entered on FLSD Docket 08/13/2020 Page 7 of 10
6. While the Plaintiff was walking into one of the aisles of the children's department 

of the Premises, she tripped and fell on carpet that was frayed and partially pulled up. 

7. Defendant negligently allowed the frayed and partially rolled up carpet to remain 

on the floor so as to constitute a tripping hazard. 

8. Defendant was negligent in ways that include, but are not limited to, the following: 

a. Defendant failed to warn patrons of a potentially hazardous condition; 

b. Defendant failed to take precautions to protect patrons walking through the 

store; and 

c. Defendant allowed a dangerous condition to exist. 

9 As a direct and proximate result of the Defendant's negligence, the Plaintiff 

suffered bodily injury for which she required surgery and incurred substantial medical expenses. 

Plaintiff also suffered resulting pain and suffering, disability, disfigurement, loss of capacity of the 

enjoyment of life, and expenses of medical and nursing care and treatment. The losses are either 

permanent-or continuing as Plaintiff will suffer the losses in the future. 

COUNT I — NEGLIGENCE 

10. Plaintiff realleges and reincorporates by reference Paragraphs 1-9 as if fully set 

forth herein. 

11. On or about July 4, 2018, Plaintiff was a customer and business invitee of the 

Defendant, lawfully on its premises at the Premises. 

12. While the Plaintiff was walking into one of the aisles of the children's department 

of the Premises, she tripped and fell on carpet that was frayed and partially pulled up. 

2 

Case 2:20-cv-14285-KMM Document 1-2 Entered on FLSD Docket 08/13/2020 Page 8 of 10
13. At all times material hereto, Defendant exercised control over the premises and its 

carpeting and knew, or should have known, that the carpet posed a danger to persons such as the 

Plaintiff. 

14. Defendant, through its agents and/or employees, owed a duty to persons such as the 

Plaintiff to: 

a. Maintain its premises in a reasonably safe condition; 

b. Correct the dangerous condition of the carpet of which Defendant knew, or 

should have known, by use of reasonable care; 

c. Warn the Plaintiff of any condition of which it knew or should have known by 

use of reasonable care was dangerous and for which it had knowledge greater 

than that of the Plaintiff; and 

d. Hire competent individuals to perform maintenance and/or inspections of the 

carpet. 

15. Defendant, by and through its agents and/or employees, breached its duty owed to 

the Plaintiff in that it failed to: 

a. Maintain its premises in a reasonably safe condition; 

b. Correct the dangerous condition of the carpet of which Defendant knew, or 

should have known, by use of reasonable care; 

c. Warn the Plaintiff of any condition of which it knew or should have known by 

use of reasonable care was dangerous and for which it had knowledge greater 

than that of the Plaintiff; 

d. Make certain that the carpet was properly maintained; and 

e. Hire competent individuals to perform maintenance on the carpet. 

3 

Case 2:20-cv-14285-KMM Document 1-2 Entered on FLSD Docket 08/13/2020 Page 9 of 10
16. As a direct and proximate result of the actions or inactions of the Defendant and its 

agents or employees, the Plaintiff suffered bodily injury for which she required surgery and 

incurred substantial medical expenses. Plaintiff also suffered resulting pain and suffering, 

disability, disfigurement, loss of capacity of the enjoyment of life, and expenses of medical and 

nursing care and treatment. The losses are either permanent or continuing as Plaintiff will suffer 

the losses in the future. 

WHEREFORE, Plaintiff demands judgment against Defendant for damages, for costs, and 

any other relief this Court deems appropriate. 

DEMAND FOR JURY TRIAL 

Plaintiff hereby demands trial by jury of all issues so triable as of right. 

Dated this 9th day of July, 2020. 

TIRADO-LUCIANO & TIRADO 

Counsel for Plaintiff 

2655 Le Jeune Road Suite 1109 

Coral Gables, Florida 33134 

305-390-2320 - Telephone 

305-390-2321 - Facsimile 

By: /s/ Alex Tirado-Luciano 

ALEJANDRO TIRADO-LUCIANO, ESQ. 

Florida Bar No. 70894 

atl@TLTirado.com MONICA TIRADO, ESQ. 

Florida Bar No.: 55877 

mtO,TLTirado.com 

4 

Case 2:20-cv-14285-KMM Document 1-2 Entered on FLSD Docket 08/13/2020 Page 10 of 10