Filing # 1.08819986 E-Fi led 06[12/2020 06:09:09 PM 

IN THE CIRCUIT COURT OF THE 

FIFTEENTH JUDICIAL CIRCUIT 

IN AND FOR PALM BEACH COUNTY, 

FLORIDA 

CASE NO.: ----6c,I.on,20,niloct6S6.02)eg,izX 016 

LISA OLLIS, 

V. 

WAL-MART STORES 

EAST, L.P. 

Defendant. 

COMPLAINT 

COMES NOW the Plaintiff, LISA OLLIS, by and through her undersigned counsel, and 

hereby sues the Defendant, WAL-MART STORES EAST, L.P., and alleges as follows: 

GENERAL ALLEGATIONS 

• I. This is a claim for damages in excess. of Thirty Thousand Dollars ($30,000.00), 

exclusive of interest and costs. 

2. The Plaintiff, LISA OLLIS, was and is at all times material hereto •a resident of 

Palm Beach County, Florida. 

3. At all times material to the cause herein, the Defendant, WAL-MART STORES 

EAST, LP, was a Foreign Company authorized to, do business in the State of Florida .and was 

engaging in retail operations at: 4375 Belvedere Road, West Palm Beach, Palm Beach County, 

Florida. 

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Case 9:20-cv-81174-RKA Document 1-2 Entered on FLSD Docket 07/17/2020 Page 1 of 4
4. On of about, May 19, 2019, Defendant owned, maintained and/or controlled a 

WAL-MART STORES EAST, L.P. store located at 437$ Belvedere Road in West Palm Beach, 

Florida. 

5. At all times material to the cause herein, the Defendant, WAL-MART .STORES 

EAST, I,P, was open to the public for retail business. On May 19,2019, the Plaintiff; LISA 

OLLIS, was a business patron/invitee at the aforementioned store as operated and controlled by 

the Defendant, WAL-MART STORES EAST, LP. 

6. On the above date and time, the Plaintiff, LISA OLLIS, while exercising due care 

and caution for her own safety, was shopping at said WAL-MART STORES EAST, L.P., and was 

caused to fall to the floor due to the careless and negligent manner in which the floors were 

maintained in the store aisles. More specifically, the Plaintiff slipped, on foreign substance on the 

floor of an aisle in the store. 

COUNT I — NEGLIGENCE OF WAL-MART STORES AS L.P. 

Plaintiff readopted and realleges each and .every allegation contained in paragraphs 1 

through 6 as if they were fully set forth herein. 

7. The Defendant, WAL-MART STORES EAST, L.P., and its employees owned to 

the Plaintiff a duty of reasonable care to maintain the shopping areas in a condition reasonably 

safe for their intended uses and free form all conditions which would render them dangerous and 

unsafe for the Plaintiff, or present an unreasonable risk of harm to her, in her lawful use of the 

8. The Defendant, WAL-MART STORES EAST, L.P., was negligent in one or more 

of the following ways: 

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a. Creating a condition that caused or allowed bleach to pool on the floor where 

patrons walk. 

b. Failure to correct a dangerous condition the Defendant knew or said should 

have known existed. 

c. Failing to put wet floor signs by the spilled bleach. 

d. The Defendant failed to properly maintain and examine the floors to make 

sure they were safe and free from liquids. 

e. The Defendant should have exercised reasonable steps in the care of its 

floors. 

f. The Defendant failed to warn the Plaintiff of the dangerous conditions. 

g. The aforedescribed dangerous condition was a regular, reoccurring, and 

ongoing condition; therefore, Defendant knew, or in the exercise of 

reasonable care, should have known of the aforedescribed dangerous and 

hazardous condition. 

h. The Defendant should have properly trained its personnel to observe, inspect 

and notice liquids on the floors and to clean such liquids. 

9. That the aforesaid acts of negligence on the parts of WAL-MART STORES EAST, 

L.P. were in proximate cause of the injuries sustained by the Plaintiff. 

JO. As a direct and proximate result of the negligence of the Defendant, WAL-MART 

STORES EAST, LP, the Plaintiff LISA DLL'S, suffered bodily injury and resulting pain and 

suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, 

expense of hospitalization, medical and nursing care and treatment, loss of earnings, loss of the 

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ability to earn money and aggravation of a previously existing condition. The losses are either 

permanent or continuing and the Plaintiff, LISA ()LLB, will suffer the losses in the future. 

WHEREFORE, the Plaintiff, LISA OLLIS, demands judgment for damages against the 

Defendant, WAL-MART STORES EAST, LP, and would further demand a trial by jury of all 

issues so triable. 

Dated this 17* day of June, 2020. 

SCHULER, HALVORSON, WEISSER, 

ZOELLERA OVERBECK, P.A. 

Attorneys for Plaintiff 

1615 Forum Place, Ste. 4-D 

Barristers Building 

West Palm Beach, FL 33401 

(561)-6,89-8180 

jweisser@shw-law.com;michele@shw-law.com; 

rchew@shw-law.com: mdickenson@shw-law.corn 

dards aOshw-law.co 

By: 

son D. Weisser 

Ia. Bar No.: 101435 

Michael D. Dickenson 

Fla. Bat No.: .90011 

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