JOSPEH ABRUZZO 

As Clerk of the Court 

By: 

As Deputy Clerk Sandrine Grab 

CASE NUMBER: 502022CA008189XXXXMB Div: AJ **** 

Filing # 155838488 E-Filed 08/22/2022 04:32:02 PM 

IN TRE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 

IN AND FOR PALM BEACH COUNTY, FLORIDA 

CASE 

KARINA MEZZASALMA, 

Plaintiff, 

V. 

TARGET CORPORATION, a foreign. 

corporation, 

Defendant. 

CIVIL ACTION SUMMONS 

THE STATE OF FLORIDA: 

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 defendants: 

TARGET CORPORATION 

do Registered Agent 

CT Corporation System 

1200 South Pine Island Road 

Plantation, Florida 33324 

Each defendant is required to serve written defenses to the complaint or petition on Thompson 

Legal, P.A., Plaintiff's attorney, whose address is: 5989 Stirling Road, Davie, FL 33314 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. 

Aug 24 2022. DATED on day of ,2022. 

FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 08/2212022 04:32:02 PM 

Exhibit 2

Case 9:22-cv-81480-WM Document 1-2 Entered on FLSD Docket 09/22/2022 Page 1 of 4
IN THE CIRCUIT COURT OF TuE FIFTEENTH JUDICIAL CIRCUIT 

IN AND FOR PALM BEACH COUNTY, FLORIDA 

CASE 

KA !UNA M EZZASA LMA, 

Plainta. 

V. 

TA RGEr CORPORATION, a foreign 

corpora 11011. 

Defendant. 

COMPLAINT'FOWDAM AG ES 

. . 

COMES NOW, KARINA MEZZASALMA (hereinafter Plaintiff), by and through the 

undersigned counsel, and sues the Defendant, TARGETCORPORATION (hereinqiier 

Defendant), and alleges as .follows: 

This is an action for damages which exceed the sum of Thirty Thousand Dollars 

($30,000.00), exclusive of interest and costs. 

2. At all times material hereto, the Plaintiff was a natural person residing in Palm 

Beach County, Florida and otherwise sui jwls. 

3. At all dines material hereto, Defendant was and is a foreign corporation authorized; 

licensed, and doing business in the State of Florida. 

4. Defendant is subject to the jurisdiction of this Court because it operates, conducts, 

engages in, or carries on a business or business venture within this State and within Palm Beach 

County; caused injury to persons or property arising out °Ian act or omission it committed within 

this State and within Palm Beach County; and engages in substantial and not isolated activity 

within this State and. Palm Beach County. 

Defendant owned, controlled, operated, staffed, managed, and/or nvaintained the 

Case 9:22-cv-81480-WM Document 1-2 Entered on FLSD Docket 09/22/2022 Page 2 of 4
premises located at 650 North Congress Avenue, Boynton Beach, Honda 33426 (hereinafter the 

Premises). 

6. Venue is proper in Palm Beach County, Florida because the incident which is the 

subject of this Complaint occurred in Palm Beach County, Florida. 

7. On or about September 6, 2021, the Plaintiff was an invitee at the Premises and 

lawfully on the Premises. 

8. Plaintiff, while walking away from the self-checkout area, slipped on a puddle of 

yellow liquid which was in the front area near the optical department due to the careless and 

negligent manlier in which the floors were maintained. 

COUNT I NEGLICENCE 101 ARCFET CORPORATION 

9. Plaintiff hereby adopts and incorporates the allegations set forth in Paragraphs 1-8 

of Mc Coinplaint as if fully set tbrth herein. 

10. The Defendant owed the Plaintiff a duty ofreasonable care to maintain the Premises 

in a condition reasonably sak for the intended uses and free from all conditions which would 

render them dangerous or unsafe for the Plaintiff, andlor present an unreasonable risk of harm to 

Plaintiliduring Plaintiffs lawful use of the Premises. This includes a reasonable effort to keep the 

Premises free Crm hazardous conditions that could have foresecably given rise to loss, injury, or 

damage. 

Defendant breached its duty because it negligently allowed a yellow liquid to 

accumulate in a highly trafficked area, creating a hazard and dangerous condition for business 

invitees entering and leaving the premises, and failed to properly maintain a clear walkway or 

throughway or warn of the presence of this dangerous condition. 

Case 9:22-cv-81480-WM Document 1-2 Entered on FLSD Docket 09/22/2022 Page 3 of 4
12. As a result of the negligence of Defendant, the Plaintiff was injured on the 

Premises. As a direct and proximate result of the negligence of Defendant and want of due and 

reasonable care., the Plaintiff suffered severe bodily injury and resulting pain and sufferin2.. 

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

expenses of hospitalization and medical and nursing care treatment, loss of earnings, loss of 

employment benefits, and loss of the ability to earn money. The injuries are either permanent or 

continuing in nature and the Plaintiff will suffer the losses and impairment into the rIllUTC. 

WHEREFORE, KARINA MEZZASALMA demands judgment against Defendant, 

TARGET CORPORATION, for bodily injury and resulting pain and suffering, disability, 

disfigurement, mental anguish, and. loss of capacity for the enjoyment of life; for all medical and 

incidental expenses according to proof; for all loss of earnings, loss of employment benefits, and 

loss of earnings capacity; for costs of suit incurred in connection with this action; and for such 

other and further relief as the Court may deem proper. 

DEMAND FOR JURY TRJA1, 

Plaintiff further demands a trial by jury on all issues so triable as a matter of right by jury. 

Dated (his August 22, 2022. 

Respectfully submitted, 

'FROM ['SON LEGAL P.A. 

Counsel/w' 

5989 Stirling Road 

Davie, FL, 33314 

Phone: 954-510-3366 

Steve Thompson, Esq. 

FL Bar No. 066269 

Stephanie Taylor, Esq. 

FL Bar No. 91233 

Email: Pleadings@ThompsonLegan—com 

Case 9:22-cv-81480-WM Document 1-2 Entered on FLSD Docket 09/22/2022 Page 4 of 4