Case Number: CACE-22-006246 Division: 14 

Filing #.148618862 E-Filed 04/28/2022 05:56:42 PM 

IN THE CIRCUIT COURT OF THE 17T" JUDICIAL CIRCUIT 

IN AND FOR BRO WARD COUNTY, FLORIDA 

HILDA ADRIANA PANCHAME, 

Plaintiff, 

V. 

TARGET COPORATION, CIVIL DIVISION 

Defendant. CASE NO.: 

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL 

The Plaintiff, HILDA ADRIANA PANCHAME, by and through the undersigned counsel, 

hereby sues the Defendant, TARGET COPORATION and alleges: 

1. This is an action for damages which exceeds Thirty Thousand Dollars ($30,000.00) 

exclusive of interest and costs, and otherwise within this Court's jurisdictional limits. 

2. At all times material hereto, the Plaintiff, HILDA ADRIANA PANCHAME, was and is 

a resident of Broward County, Florida, and is otherwise sui furls. 

3. At all times material hereto, the Defendant, TARGET COPORATION, was and is a 

foreign corporation doing business in Broward County, Florida. 

4. Venue is proper in this County in that the Defendant does business in Broward 

County, Florida, and/or all of the acts complained of herein occurred in Broward County, Florida. 

5. On or about December 24, 2020, the Plaintiff, HILDA ADRIANA PANCHAME, was a 

business invitee of the Defendant, TARGET COPORATION, at its premises located at 16901 

Miramar Parkway, Miramar, Florida. 

*** FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 04/28/2022 05:56:40 PM.**** 

Case 0:22-cv-61040-WPD Document 1-1 Entered on FLSD Docket 06/02/2022 Page 1 of 4
At all times material hereto, and specifically on December 24, 2020, Defendant, 

TARGET COPORATION, owned, managed, controlled, operated, and/or maintained the premises 

located at 16901 Miramar Parkway, Miramar, Florida. 

7. On or about December 24, 2020, the Plaintiff, Hilda Adriana Panchame, was 

lawfully present at Defendant, TARGET COPORATION'S, aforementioned premises, when she 

slipped in liquid and fell. 

8. The Defendant owed to its business invitees a duty to provide a reasonably safe 

environment. 

9. The Defendant, its agents, servants or employees, breached its duty owed to the 

Plaintiff by negligently maintaining its premises in the following manner: 

a. By failing to maintain the floor of the premises in a reasonably safe 

condition, to wit, allowing liquids and/or other substances to accumulate on the floor, and to 

prevent dangerous conditions from occurring; and/or 

b. By failing to warn of the dangerous condition that existed at the time of 

the Plaintiff's incident; and/or 

c. Failing to place barricades, wet floor signs, or other marking devices 

utilized to alert customers such as the Plaintiff of the dangerous condition that existed at the 

time of Plaintiff's incident; and/or 

d. By failing to remove said liquid or other substance from the floor of the 

premises; and/or 

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e. By failing to correct the hazardous condition of the premises when the 

Defendant knew or should have known that the general public visits said premises and specifically 

the Plaintiff herein; and/or 

f. Was otherwise negligent in the care, maintenance, and upkeep of the 

premises, and specifically by allowing a liquid and/or another substance to be left on the floor of 

the premises so as to cause the Plaintiff to fall. 

10. That the Defendant knew or in the exercise of reasonable care should have known 

of the existence of the hazardous and dangerous condition and the condition had existed for a 

sufficient length of time that the Defendant knew or should have known of the condition and 

could have easily remedied it; and/or 

11. That the dangerous condition occurred with such frequency that owner should 

have known of its existence. 

12. As a direct and proximate result of the aforementioned negligence of the 

Defendant, TARGET COPORATION, the Plaintiff, HILDA ADRIANA PANCHAME, sustained severe, 

grievous and permanent injuries, physical and mental pain and suffering, disability, physical 

impairment, disfigurement, mental anguish, inconvenience, loss of capacity for the enjoyment of 

life, loss of earnings and impairment of earning capacity and/or permanent aggravation of a preexisting condition, and further incurred hospital bills, medical bills, and/or other bills as a result 

of said injuries; said injuries are either permanent or continuing in their nature and the Plaintiff, 

HILDA ADRIANA PANCHAME will suffer the losses into the future. 

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DEMAND FOR JURY TRIAL 

The Plaintiff, HILDA ADR1ANA PANCHAME, hereby demands trial by jury of all issues so 

triable as a matter of right. 

Dated: 

RUBENSTEIN LAW, P.A. 

Attorneys for Plaintiff 

RUBENSTEIN LAW, P.A 

9130 S. Dadeland Blvd, PH 

Miami, FL 33156 

Tel: (305) 661-6000 

Fax: (305) 670-7555 

Email: meranda@rubensteinlaw.com 

jdolfi@rubensteinlaw.com 

eservice@rubensteinlaw.com 

By: is/ Meranda Reifschn eider 

Meranda Reifschneider 

Florida Bar No.: 091970 

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