EXHIBIT A 

Case 2:22-cv-14333-AMC Document 1-1 Entered on FLSD Docket 09/20/2022 Page 1 of 4
Filing # 155611771 E-Filed 08/18/2022 11:55:37 AM 

IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT, 

IN AND FOR INDIAN RIVER COUNTY, FLORIDA 

HEIDI E. LOPEZ, 

Plaintiff, 

v. CASE NO.: 

WAL-MART STORES EAST, LP D/B/A 

WALMART SUPERCENTER, STORE 

#931, 

Defendant. 

/ 

COMPLAINT 

Plaintiff, HEIDI E. LOPEZ, sues Defendant, WAL-MART STORES 

EAST, LP D/B/A WALMART SUPERCENTER, STORE #931, and hereafter 

allege: 

1. This is an action for damages that exceeds THIRTY THOUSAND 

DOLLARS AND 00/100 ($30,000.00). 

2. Plaintiff, HEIDI E. LOPEZ, is over the age of eighteen years and a 

resident of Indian River County, Florida. 

3. Defendant, WAL-MART STORES EAST, LP, is a for-profit corporation 

formed under the laws of the state of Florida, and at all times herein was doing 

business as WALMART SUPERCENTER, STORE #931. 

4. On or about 3/19/2021, Defendant, WAL-MART STORES EAST, LP, 

owned, operated, managed and/or maintained a certain premise, commonly 

Case 2:22-cv-14333-AMC Document 1-1 Entered on FLSD Docket 09/20/2022 Page 2 of 4
known as WALMART SUPERCENTER, STORE #931, located at 5555 20th 

Street, Vero Beach, FL 32966. 

5. At the aforesaid time and place, Plaintiff, HEIDI E. LOPEZ, a 

business invitee, was lawfully on the premise commonly known as WALMART 

SUPERCENTER, STORE #931, located at or about 5555 20th Street, Vero 

Beach, FL 32966. 

6. At the aforesaid time and place, Defendant created a dangerous 

condition on the floor and failed to warn of the dangers such that the Plaintiff 

slipped and fell which resulted in significant injuries. 

7. Plaintiff reasserts and re-alleges all paragraphs set forth above as if 

fully set forth herein. 

8. At the aforesaid time and place, Defendant, WAL-MART STORES 

EAST, LP, had a duty to maintain the aforementioned premises in a reasonably 

safe condition for persons lawfully on said premised, including Plaintiff, and to 

warn of any dangerous conditions. 

9. At the aforesaid time and place, Defendant, WAL-MART STORES 

EAST, LP, failed to maintain the aforementioned property in a reasonably safe 

condition. Defendant allowed a dangerous condition to exist, specifically allowing 

water to be on the floor from a leaking freezer, failing to clean it up, and failing to 

warn of its danger. 

10. As a direct and proximate result of Defendant's, WAL-MART STORES 

EAST, LP negligence, Plaintiff, HEIDI E. LOPEZ, slipped and fell and suffered 

bodily injury, disability, disfigurement, mental anguish and pain, loss of earnings, 

Case 2:22-cv-14333-AMC Document 1-1 Entered on FLSD Docket 09/20/2022 Page 3 of 4
loss of ability to earn money and aggravation of a previously existing conditions, 

and has incurred substantial medical expenses for treatment and care, past, 

present suffered pain there from, incurred medical expenses for treatment and 

care, past, present and future, his working ability was impaired, the injuries are 

either permanent or continuing in nature, and Plaintiff will suffer the losses and 

impairment in the future. 

WHEREFORE, Plaintiff demands judgment against Defendant, WALMART STORES EAST, LP D/B/A WALMART SUPERCENTER, STORE #931, for 

all allowable damages, interest, costs and any such other relief the court deems 

necessary and proper. 

Plaintiff further demand a trial by jury. 

DATED this 18th day of August, 2022. 

/s/ Victoria M. Manolardi 

Victoria M. Manglardi 

Florida Bar No.: 93604 

Martinez Manglardi, P.A. 

4651 Babcock Street NE, 

Suite 6A 

Palm Bay, FL 32905 

Telephone: (321) 312-4545 

Facsimile: (321) 312-4544 

victoria@martinezmanglardi.com 

espada@martinezmanglardi.com 

Attorney for Plaintiff 

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