UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

RACHEL LORENZO,

Plaintiff

v.

SHARKNINJA MANAGEMENT LLC 

and SHARKNINJA OPERATING LLC, 

Defendants

 Case No. _________

DEFENDANTS’ NOTICE OF REMOVAL

Defendants SharkNinja Management LLC and SharkNinja Operating LLC (the 

“Defendants”) remove this products-liability action filed on August 2, 2022, from the Eleventh 

Judicial Circuit Court in and for Miami-Dade County, Florida to this Court on the basis of diversity 

jurisdiction under 28 U.S.C. §§ 1332, 1441, and 1446.

GROUNDS FOR REMOVAL – DIVERSITY JURISDICTION

The grounds for removal based on diversity jurisdiction are met. As to the completediversity requirement, Plaintiff Rachel Lorenzo is a citizen of Florida, see Plaintiff’s First 

Amended Complaint at ¶ 2 (attached as Ex. B), and neither Defendant is a citizen of Florida. 

SharkNinja Management LLC is a Delaware limited liability company with its principal place of 

business in Massachusetts, wholly owned by its sole member, SharkNinja Operating LLC. 

SharkNinja Operating LLC is a Delaware limited liability company with its principal place of 

business in Massachusetts, whose sole member is EP Midco LLC, a Delaware limited liability 

company with its principal place of business in Massachusetts, whose sole member is Global 

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 1 of 86
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Appliance LLC, a Delaware limited liability company with its principal place of business in 

Massachusetts, whose sole member is Global Appliance UK Holdco Ltd., a corporation organized 

under the laws of the United Kingdom with its principal place of business located in England.

As to the amount-in-controversy requirement, Plaintiff’s October 16, 2020, demand letter

sought $1,000,000—well in excess of $75,000. Plaintiff’s $1,000,000.00 demand was based, in 

part, on Plaintiff’s medical bills of $51,202.50 (which are totaled up in the demand letter, and 

attached thereto), relating to her claim that SharkNinja’s defective blender caused her “serious 

injuries” when the blade fell out and lacerated her right foot, requiring surgery for a “ruptured 

tendon” (shown in photos attached to the demand letter).1

Plaintiff’s October 16, 2020, Timed Demand Letter. 

Plaintiff’s First Amended Complaint also includes damages for pain and suffering, disfigurement, 

mental anguish, loss of capacity or the enjoyment of life, the expense of hospitalization, medical 

and nursing care treatment, rehabilitative expenses, and inconvenience. See First Amended 

Complaint, ¶ 108. Plaintiff also seeks demands court costs. Id. On these facts, the amount-incontroversy requirement is satisfied. See Gillinov v. Hillstone Rest. Grp., Inc., 92 F. Supp. 3d 1251, 

1254-55 (S.D. Fla. 2015) (noting that district courts may consider demand letter “when 

determining whether the amount in controversy requirement is satisfied”); Kilmer v. Stryker Corp., 

No. 5:14-CV-456-OC-34PRL, 2014 WL 5454385, at *4 (M.D. Fla. Oct. 27, 2014) (holding that 

pre-suit demand letter, which specified past medical expenses combined with claims for permanent 

 

1 After making the $1,000,000.00 demand, Plaintiff’s counsel subsequently lowered the demand 

to $900,000.00 and then again to $450,000.00—and then Plaintiff filed this lawsuit. 

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 2 of 86
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injury, pain and suffering, and past and future economic loss, was sufficient evidence that the 

amount-in-controversy requirement was met); Floyd v. Wal Mart Stores East LP, No. 3:12-cv336/RS-CJK, 2012 WL 3155784 (N.D. Fla. Aug. 3, 2012) (holding that it is acceptable to disclose 

a confidential settlement demand when determining whether the amount-in-controversy 

requirement has been satisfied). 

PROCEDURAL REQUIREMENTS FOR REMOVAL

The procedural requirements for removal are also met. This Court is the proper venue for 

an action removed from Miami-Dade County. This Notice of Removal is timely because it was 

filed within 30 days of September 6, 2022, the date SharkNinja Management LLC was served with

Plaintiff’s Original Complaint, which is the first paper from which it could be ascertained that this 

case is removable.2

After filing this notice of removal, Defendants will promptly give written notice thereof to 

all adverse parties and shall file a copy of the notice with the clerk of Miami-Dade County’s 

Eleventh Judicial Circuit Court, pursuant to 28 U.S.C. § 1446(d) and the Local Rules of this Court, 

Defendants have attached the following exhibits, which include a legible copy of each paper 

docketed in the state court:

 Plaintiff’s Complaint (Ex. A)

 Plaintiff’s First Amended Complaint (Ex. B)

 Civil Cover Sheet (Ex. C) 

 Index of all papers docketed in the state court action (Ex. D)

 

2 Plaintiff added Defendant SharkNinja Operating LLC to this action in its First Amended 

Complaint, filed on September 8, 2022. SharkNinja Operating LLC joins SharkNinja Management 

LLC in this Notice of Removal. 

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 Copies of all papers docketed in the state court action (Ex. E)

In accordance with Local Rule 7.2, Defendants assert that there are no pending motions 

previously filed in this action. 

WHEREFORE, Defendants SharkNinja Management LLC and SharkNinja Operating 

LLC, respectfully request this Court to assume jurisdiction of the above-styled action now pending 

in the Eleventh Judicial Circuit in and for Miami-Dade County, Florida. 

Dated: September 26, 2022. Respectfully submitted,

/s/ Scott D. Kaiser

Scott D. Kaiser 

Florida Bar No. 95208 

SHOOK, HARDY & BACON L.L.P. 

2555 Grand Blvd. 

Kansas City, MO 64108 

(816) 474-6550 

skaiser@shb.com

Counsel for Defendants 

SharkNinja Management LLC 

and SharkNinja Operating LLC

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CERTIFICATE OF SERVICE

This is to certify that I have this 26th day of September, 2022, electronically filed the 

foregoing with the Clerk of Court for the United States District Court, Southern District of Florida, 

by using the CM/ECF system and served the following parties by electronic mail: 

Matthias M. Hayashi

Spencer M. Aronfeld

Abby H. Ivey

ARONFELD TRIAL LAWYERS

One Alhambra Plaza Penthouse

Coral Gables, Florida 33134

mhayashi@aronfeld.com

aronfeld@aronfeld.com

aivey@aronfeld.com

Attorneys for Plaintiff

/s/ Scott D. Kaiser

Counsel for Defendants 

SharkNinja Management LLC 

and SharkNinja Operating LLC

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EXHIBIT A

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IN THE CIRCUIT COURT FOR THE 

ELEVENTH JUDICIAL CIRCUIT IN AND 

FOR MIAMI-DADE COUNTY, FLORIDA 

CASE NO. 

GENERAL JURISDICTION DIVISION 

RACHEL LORENZO, 

Plaintiff, 

v.

SHARKNINJA MANAGEMENT LLC, 

Defendant. 

________________________________/ 

COMPLAINT FOR DAMAGES 

AND DEMAND FOR TRIAL BY JURY 

Plaintiff, RACHEL LORENZO (hereinafter “LORENZO”), through undersigned counsel, 

sues Defendant, SHARKNINJA MANAGEMENT LLC, (hereinafter “SHARKNINJA”), and 

demands trial by jury, stating as follows: 

PARTIES AND JURISDICTION 

1. LORENZO seeks damages in excess of Thirty Thousand Dollars ($30,000.00),

exclusive of interest, costs, and attorneys’ fees. 

2. LORENZO was and is at all times a citizen and resident of Miami-Dade County,

Florida. 

3. LORENZO sustained serious and permanent injuries in an incident which occurred

on November 3, 2019 in Miami-Dade County, Florida. 

4. SHARKNINJA was at all times material a foreign corporation authorized to do business

and doing business in the state of Florida, engaged in the business of designing, testing, fabricating, 

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manufacturing, assembling, producing, distributing and selling home kitchen appliances, including 

the Ninja Master blender model QB900B (hereinafter the “subject blender”). 

5. At all times material, the subject blender was in substantially the same condition as when

it left the respective manufacturer’s and consumer seller’s possession, and there were no changes 

made to the subject blender between the time it left SHARKNINJA’ possession and the time of the 

subject incident. 

6. On November 3, 2019, LORENZO was operating the subject blender when it suddenly

and unexpectedly disgorged its blade, which sliced through her right foot, toes, and/or tendons. 

Furthermore, the subject blender had no support to hold the blade. 

7. The defects inherent in the subject blender were not reasonably discoverable by

LORENZO and were unknown to her at the time and place of the incident. 

8. As a result, LORENZO sustained serious and permanent injuries.

COUNT I 

STRICT LIABILITY CLAIM AGAINST SHARKNINJA

9. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein.

10. The subject blender was defective and unreasonably dangerous by virtue of its condition

and the failure to warn of known and foreseeable risks, insofar as it was subject to disgorgement of 

its sharp and dangerous blade suddenly and unexpectedly in the course of foreseeable use, and insofar 

as the subject blender had no support to hold the blade 

11. The subject defect existed at the time it left the possession and control of

SHARKNINJA, and, at the time it came into the possession of LORENZO. 

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12. The subject blender had not been altered and/or damaged prior to the time of the incident

described herein and was in substantially the same condition at the time of the incident described as 

at the time it was manufactured and sold by SHARKNINJA and placed in the stream of commerce. 

13. At all relevant times, SHARKNINJA was in the business of designing, manufacturing,

inspecting, testing, distributing, selling and/or marketing blenders and did design, manufacture, 

inspect, test, distribute, sell and/or market the subject blender. 

14. The subject blender failed to perform in a manner reasonably expected in light of its

nature and intended function when it failed and caused severe injuries. 

15. The subject blender had not been misused post-sale before it failed.

16. The subject blender was within its anticipated useful life when it failed.

17. The subject blender’s failure was such that would not have occurred in the absence of a

defect or unreasonably dangerous condition within it. 

18. Specifically, the subject blender was unreasonably dangerous and/or defective in that:

a. it was dangerous to an extent beyond that which would be contemplated by the

ordinary consumer who purchases and/or uses it, with the ordinary knowledge 

common to the community as to its characteristics; and/or 

b. a reasonably prudent manufacturer would not have put it on the market assuming

that manufacturer knew of its dangerous condition. 

19. As a direct and proximate result of the defective and unreasonably dangerous conditions

of the subject blender, it suddenly and without warning disgorged its sharp and dangerous blade, 

which lacked adequate support to hold it, causing LORENZO’s incident and serious injuries. 

20. As a direct and proximate result of the defective and unreasonably dangerous condition

of the subject blender and the resulting incident as described, LORENZO suffered bodily injury and 

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resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future. 

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against 

Defendant, SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in 

excess of Thirty Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues

triable as of right by a jury. 

COUNT II 

NEGLGIENCE CLAIM AGAINST SHARKNINJA 

21. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein. 

22. At all times material SHARKNINJA had a duty to LORENZO to exercise reasonable

care in the design, testing and manufacture of the subject blender as described in the incident above. 

23. SHARKNINJA knew, or in the existence of ordinary care, should have known, that the

subject blender was defective and unreasonably dangerous to those persons likely to use the product 

for the purpose and in the manner for which it was intended to be used. For example, SHARKNINJA 

has previously been sued in this circuit, district, and throughout this nation for similar malfunctions. 

See Wallace et al. v. Sharkninja Operating LLC, Case 5:18-cv-05221-BLF; see also Warner v. 

Sharkninja Operating LLC, Case 3:22-cv-00310-JCS; see also Mawla, et al. v. Sharkninja Operating, 

LLC, Case 3:21-cv-05202-JD; see also Moberly v. Sharkninja Operating LLC, et al., Case 2:22-cv14259-AMC; see also Gallo, et al., v. BJ’S WHOLESALE CLUB, INC., et al., Case 1:20-cv-22907-

CMA. 

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24. Alternatively, SHARKNINJA knew, or in the exercise of ordinary care should have 

known, of the means of designing, manufacturing and/or marketing the subject blender such that the 

type of incident and resulting injuries and damages as described herein would have been prevented. 

25. Alternatively, SHARKNINJA had actual or constructive knowledge of the means of 

designing a blender that would not be inadequate and dangerous, and notwithstanding this knowledge, 

SHARKNINJA failed to adequately design, equip and/or manufacture the subject blender. 

26. Alternatively, SHARKNINJA negligently failed to give adequate warnings or 

instructions, and/or failed to make appropriate post-marketing efforts to prevent known incidents, 

such as the one included herein. 

27. Alternatively, SHARKNINJA failed to adequately design, manufacture, test, inspect, 

market and/or sell the subject blender, and/or failed to include a reasonable and safer alternative to 

the subject defective condition. 

28. Alternatively, SHARKNINJA failed to adequately monitor consumer injury and damage 

reports associated with the subject blender, and/or failed to include a reasonable and safer alternatives 

to the subject defective condition. 

29. As a direct and proximate result of SHARKNINJA’s negligence, the subject blender 

suddenly and without warning disgorged its sharp and dangerous blade, which lacked adequate 

support to hold it, causing LORENZO’s incident and serious injuries. 

30. As a direct and proximate result of SHARKNINJA’s negligence, LORENZO suffered 

bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of 

capacity for the enjoyment of life, the expense of hospitalization, medical and nursing care and 

treatment, rehabilitative expenses, and inconvenience. The losses are permanent and continuing in 

nature and LORENZO will suffer these losses in the future. 

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WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Thirty

Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues triable as of right by a 

jury. 

COUNT III

BREACH OF EXPRESS WARRANTY AGAINST SHARKNINJA

31. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein. 

32. SHARKNINJA designed, manufactured, assembled, distributed, inspected, tested

and/or sold the subject blender. 

33. SHARKNINJA expressly warranted that the subject blender was safe for ordinary use

when used in compliance with the instructions provided, which LORENZO followed. 

34. SHARKNINJA’s affirmations regarding the safety of its product formed a basis of the

bargain for LORENZO without which LORENZO would not have purchased and/or used the subject 

blender. 

35. The subject blender did not conform to SHARKNINJA’s affirmations regarding safety.

36. As a direct and proximate result of SHARKNINJA’s breach of express warranties, the

subject blender suddenly and without warning disgorged its sharp and dangerous blade, which lacked 

adequate support to hold it, causing LORENZO’s incident and serious injuries. 

37. As a direct and proximate result of SHARKNINJA’s breach of express warranties,

LORENZO suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental 

anguish, loss of capacity for the enjoyment of life, the expense of hospitalization, medical and nursing 

care and treatment, rehabilitative expenses, and inconvenience. The losses are permanent and 

continuing in nature and LORENZO will suffer these losses in the future. 

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WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Thirty

Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues triable as of right 

by a jury. 

COUNT IV 

BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY AGAINST 

SHARKNINJA

38. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein. 

39. SHARKNINJA at all relevant times designed, manufactured, assembled, tested,

inspected, distributed, marketed and/or sold the subject blender. 

40. SHARKNINJA impliedly warranted that the subject blender was merchantable, fit for

the ordinary purpose for which it was sold or used, was of fair average quality as to pass without 

objection in the trade, and conformed to SHARKNINJA’s own affirmations regarding the subject 

blender’s safety features and overall safe condition. 

41. SHARKNINJA breached their implied warranty of merchantability, as the product did

not conform to SHARKNINJA’s affirmations regarding the safety features and overall safe condition 

of the subject blender, the subject blender was not fit for the ordinary purpose for which it was sold 

or used, and/or was not of fair average quality so as to pass without objection in the trade. 

42. As a direct and proximate result of SHARKNINJA’s breach of the implied warranty of

merchantability, the subject blender suddenly and without warning disgorged its sharp and dangerous 

blade, which lacked adequate support to hold it, causing LORENZO’s incident and serious injuries. 

43. As a direct and proximate result of SHARKNINJA’s breach of the implied warranty of

merchantability, LORENZO suffered bodily injury and resulting pain and suffering, disability, 

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disfigurement, mental anguish, loss of capacity for the enjoyment of life, the expense of 

hospitalization, medical and nursing care and treatment, rehabilitative expenses, and inconvenience. 

The losses are permanent and continuing in nature and LORENZO will suffer these losses in the 

future. 

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Thirty

Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues triable as of right 

by a jury. 

COUNT V 

BREACH OF IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR 

PURPOSE AGAINST SHARKNINJA 

44. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein. 

45. SHARKNINJA designed, manufactured, assembled, tested, inspected, distributed,

marketed and/or sold the subject blender. 

46. In selling the subject blender to LORENZO, SHARKNINJA, through its agents,

servants, employees, and apparent agents, acting within the scope of their employment, authority, or 

apparent authority, made representations and promotions concerning the particular purpose to which 

LORENZO would put the subject blender to use and knew or should have known of the particular 

purpose to which LORENZO would put the product to use. SHARKNINJA impliedly warranted that 

the product would be fit for such particular purpose. 

47. SHARKNINJA breached its implied warranty of fitness for a particular purpose, as the

subject blender did not conform to SHARKNINJA’s affirmations regarding its product being fit for 

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such particular purpose. The subject blender’s malfunctioning safety features and overall unsafe 

condition rendered it unfit for that purpose. 

48. As a direct and proximate result of SHARKNINJA’s breach of the implied warranty of

fitness for a particular purpose, the subject blender suddenly and without warning disgorged its sharp 

and dangerous blade, which lacked adequate support to hold it, causing LORENZO’s incident and 

serious injuries. 

49. As a direct and proximate result of SHARKNINJA’s breach of the implied warranty of

fitness for a particular purpose, LORENZO suffered bodily injury and resulting pain and suffering, 

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

hospitalization, medical and nursing care and treatment, rehabilitative expenses, and 

inconvenience. The losses are permanent and continuing in nature and LORENZO will suffer 

these losses in the future. 

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against 

Defendant, SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in 

excess of Thirty Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues

triable as of right by a jury. 

COUNT VI

FAILURE TO WARN AGAINST SHARKNINJA

50. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein. 

51. SHARKNINJA designed, manufactured, assembled, tested, inspected, distributed,

marketed and/or sold the subject blender. 

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52. On or about November 3, 2019, LORENZO used the subject blender in the manner 

intended and/or foreseeably intended, when the subject blender failed and/or otherwise caused injury 

to LORENZO. 

53. The subject blender was manufactured in a defective manner, was defectively designed, 

failed to have adequate and proper warnings or instructions, was not safe to be used for the purposes 

intended, and/or was otherwise inherently and/or unreasonably dangerous. 

54. SHARKNINJA knew or should have known of the dangerous nature of the subject 

blender by virtue of its business, and/or knew or should have known of the need to provide adequate 

warnings concerning the use of the subject blender. For example, SHARKNINJA has previously been 

sued in this circuit, district, and throughout this nation for similar malfunctions. See Wallace et al. v. 

Sharkninja Operating LLC, Case 5:18-cv-05221-BLF; see also Warner v. Sharkninja Operating LLC, 

Case 3:22-cv-00310-JCS; see also Mawla, et al. v. Sharkninja Operating, LLC, Case 3:21-cv-05202-

JD; see also Moberly v. Sharkninja Operating LLC, et al., Case 2:22-cv-14259-AMC; see also Gallo, 

et al., v. BJ’S WHOLESALE CLUB, INC., et al., Case 1:20-cv-22907-CMA. 

55. SHARKNINJA had a duty to provide reasonable warnings of dangers involved in the 

use of the subject blender, and failed to provide the public, including LORENZO, notice of the danger 

involved. 

56. As a direct and proximate result of SHARKNINJA’s failure to warn of the dangers of 

the subject blender, LORENZO was unable to protect herself or otherwise avoid injury when her 

incident occurred. 

57. As a direct and proximate result of the foregoing, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

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rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature 

and LORENZO will suffer these losses in the future. 

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against 

Defendant, SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in 

excess of Thirty Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues

triable as of right by a jury. 

DEMAND FOR JURY TRIAL

Plaintiff, RACHEL LORENZO, demands trial by jury on all issues so triable. 

Dated: August 2, 2022. 

Respectfully submitted, 

/s/ Matthias M. Hayashi 

Spencer M. Aronfeld, Esq. 

Florida Bar No.: 905161 

aronfeld@Aronfeld.com 

Abby H. Ivey, Esq. 

Florida Bar No.: 1002774 

aivey@aronfeld.com 

Matthias M. Hayashi 

Florida Bar No.: 115973 

mhayashi@aronfeld.com 

Riana S. Maryanoff, Esq. 

Florida Bar No.: 1024768 

rmaryanoff@aronfeld.com 

ARONFELD TRIAL LAWYERS 

One Alhambra Plaza, Penthouse 

Coral Gables, Florida 33134 

P: (305) 441.0440 

F: (305) 441.0198 

Attorneys for Plaintiff 

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EXHIBIT B

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IN THE CIRCUIT COURT FOR THE 

ELEVENTH JUDICIAL CIRCUIT IN AND 

FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO. 2022-014612-CA-01 

GENERAL JURISDICTION DIVISION

RACHEL LORENZO, 

Plaintiff,

v.

SHARKNINJA MANAGEMENT LLC., 

and SHARKNINJA OPERATING LLC, 

 Defendants,

________________________________/ 

FIRST AMENDED COMPLAINT FOR DAMAGES 

AND DEMAND FOR TRIAL BY JURY

Plaintiff, RACHEL LORENZO (hereinafter “LORENZO”), through undersigned counsel, 

sues Defendants, SHARKNINJA MANAGEMENT LLC, and Defendants, SHARKNINJA 

OPERATING LLC, demands trial by jury, stating as follows:

PARTIES AND JURISDICTION

1. LORENZO seeks damages in excess of Fifteen Thousand Dollars ($15,000.00), 

exclusive of interest, costs, and attorneys’ fees.

2. LORENZO was and is at all times a citizen and resident of Miami-Dade County, 

Florida. 

3. LORENZO sustained serious and permanent injuries in an incident which occurred 

on November 3, 2019 in Miami-Dade County, Florida. 

4. SHARKNINJA MANAGEMENT LLC was at all times material a foreign corporation 

authorized to do business and doing business in the state of Florida, engaged in the business of 

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designing, testing, fabricating, manufacturing, assembling, producing, distributing and selling home 

kitchen appliances, including the Ninja Master blender model QB900B (hereinafter the “subject 

blender”).

5. SHARKNINJA OPERATING LLC was at all times material a foreign corporation 

authorized to do business and doing business in the state of Florida, engaged in the business of 

designing, testing, fabricating, manufacturing, assembling, producing, distributing and selling home 

kitchen appliances, including the Ninja Master blender model QB900B (hereinafter the “subject 

blender”).

6. At all times material, the subject blender was in substantially the same condition as when

it left the respective manufacturer’s and consumer seller’s possession, and there were no changes 

made to the subject blender between the time it left SHARKNINJA MANAGEMENT LLC’s 

possession and the time of the subject incident.

7. At all times material, the subject blender was in substantially the same condition as when

it left the respective manufacturer’s and consumer seller’s possession, and there were no changes 

made to the subject blender between the time it left SHARKNINJA OPERATING LLC’s possession

and the time of the subject incident.

8. On November 3, 2019, LORENZO was operating the subject blender when it suddenly

and unexpectedly disgorged its blade, which sliced through her right foot, toes, and/or tendons. 

Furthermore, the subject blender had no support to hold the blade. 

9. The defects inherent in the subject blender were not reasonably discoverable by 

LORENZO and were unknown to her at the time and place of the incident.

10. As a result, LORENZO sustained serious and permanent injuries. 

COUNT I 

STRICT LIABILITY CLAIM AGAINST SHARKNINJA MANAGEMENT LLC

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11. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

12. The subject blender was defective and unreasonably dangerous by virtue of its condition

and the failure to warn of known and foreseeable risks, insofar as it was subject to disgorgement of 

its sharp and dangerous blade suddenly and unexpectedly in the course of foreseeable use, and insofar 

as the subject blender had no support to hold the blade. 

13. The subject defect existed at the time it left the possession and control of SHARKNINJA 

MANAGEMENT LLC, and, at the time it came into the possession of LORENZO. 

14. The subject blender had not been altered and/or damaged prior to the time of the incident 

described herein and was in substantially the same condition at the time of the incident described as 

at the time it was manufactured and sold by SHARKNINJA MANAGEMENT LLC and placed in the 

stream of commerce.

15. At all relevant times, SHARKNINJA MANAGEMENT LLC was in the business of 

designing, manufacturing, inspecting, testing, distributing, selling and/or marketing blenders and did 

design, manufacture, inspect, test, distribute, sell and/or market the subject blender. 

16. The subject blender failed to perform in a manner reasonably expected in light of its 

nature and intended function when it failed and caused severe injuries.

17. The subject blender had not been misused post-sale before it failed.

18. The subject blender was within its anticipated useful life when it failed.

19. The subject blender’s failure was such that would not have occurred in the absence of a 

defect or unreasonably dangerous condition within it.

20. Specifically, the subject blender was unreasonably dangerous and/or defective in that:

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a. it was dangerous to an extent beyond that which would be contemplated by the 

ordinary consumer who purchases and/or uses it, with the ordinary knowledge

common to the community as to its characteristics; and/or

b. a reasonably prudent manufacturer would not have put it on the market assuming 

that manufacturer knew of its dangerous condition.

21. As a direct and proximate result of the defective and unreasonably dangerous conditions 

of the subject blender, it suddenly and without warning disgorged its sharp and dangerous blade,

which lacked adequate support to hold it, causing LORENZO’s incident and serious injuries. 

22. As a direct and proximate result of the defective and unreasonably dangerous condition 

of the subject blender and the resulting incident as described, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT II 

NEGLGIENCE CLAIM AGAINST SHARKNINJA MANAGEMENT LLC

23. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

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24. At all times material SHARKNINJA MANAGEMENT LLC had a duty to LORENZO

to exercise reasonable care in the design, testing and manufacture of the subject blender as described

in the incident above.

25. SHARKNINJA MANAGEMENT LLC knew, or in the existence of ordinary care, 

should have known, that the subject blender was defective and unreasonably dangerous to those 

persons likely to use the product for the purpose and in the manner for which it was intended to be 

used. For example, SHARKNINJA MANAGEMENT LLC has previously been sued in this circuit, 

district, and throughout this nation for similar malfunctions. See Wallace et al. v. Sharkninja 

Operating LLC, Case 5:18-cv-05221-BLF; see also Warner v. Sharkninja Operating LLC, Case 3:22-

cv-00310-JCS; see also Mawla, et al. v. Sharkninja Operating, LLC, Case 3:21-cv-05202-JD; see also 

Moberly v. Sharkninja Operating LLC, et al., Case 2:22-cv-14259-AMC; see also Gallo, et al., v. 

BJ’S WHOLESALE CLUB, INC., et al., Case 1:20-cv-22907-CMA.

26. Alternatively, SHARKNINJA MANAGEMENT LLC knew, or in the exercise of 

ordinary care should have known, of the means of designing, manufacturing and/or marketing the 

subject blender such that the type of incident and resulting injuries and damages as described herein 

would have been prevented.

27. Alternatively, SHARKNINJA MANAGEMENT LLC had actual or constructive 

knowledge of the means of designing a blender that would not be inadequate and dangerous, and 

notwithstanding this knowledge, SHARKNINJA MANAGEMENT LLC failed to adequately design, 

equip and/or manufacture the subject blender. 

28. Alternatively, SHARKNINJA MANAGEMENT LLC negligently failed to give 

adequate warnings or instructions, and/or failed to make appropriate post-marketing effortsto prevent 

known incidents, such as the one included herein.

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29. Alternatively, SHARKNINJA MANAGEMENT LLC failed to adequately design, 

manufacture, test, inspect, market and/or sell the subject blender, and/or failed to include a reasonable 

and safer alternative to the subject defective condition.

30. Alternatively, SHARKNINJA MANAGEMENT LLC failed to adequately monitor 

consumer injury and damage reports associated with the subject blender, and/or failed to include a

reasonable and safer alternatives to the subject defective condition.

31. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s 

negligence, the subject blender suddenly and without warning disgorged its sharp and dangerous 

blade, which lacked adequate support to hold it, causing LORENZO’s incident and serious injuries. 

32. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s 

negligence, LORENZO suffered bodily injury and resulting pain and suffering, disability, 

disfigurement, mental anguish, loss of capacity for the enjoyment of life, the expense of 

hospitalization, medical and nursing care and treatment, rehabilitative expenses, and inconvenience. 

The losses are permanent and continuing in nature and LORENZO will suffer these losses in the 

future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT III

BREACH OF EXPRESS WARRANTY AGAINST SHARKNINJA MANAGEMENT LLC

33. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

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34. SHARKNINJA MANAGEMENT LLC designed, manufactured, assembled, 

distributed, inspected, tested and/or sold the subject blender. 

35. SHARKNINJA MANAGEMENT LLC expressly warranted that the subject blender

was safe for ordinary use when used in compliance with the instructions provided, which LORENZO 

followed.

36. SHARKNINJA MANAGEMENT LLC’s affirmations regarding the safety of its 

product formed a basis of the bargain for LORENZO without which LORENZO would not have 

purchased and/or used the subject blender. 

37. The subject blender did not conform to SHARKNINJA MANAGEMENT LLC’s 

affirmations regarding safety.

38. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

express warranties, the subject blender suddenly and without warning disgorged its sharp and 

dangerous blade, which lacked adequate support to hold it, causing LORENZO’s incident and serious 

injuries. 

39. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

express warranties, LORENZO suffered bodily injury and resulting pain and suffering, disability, 

disfigurement, mental anguish, loss of capacity for the enjoyment of life, the expense of 

hospitalization, medical and nursing care and treatment, rehabilitative expenses, and inconvenience. 

The losses are permanent and continuing in nature and LORENZO will suffer these losses in the 

future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

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Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT IV

BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY AGAINST

SHARKNINJA MANAGEMENT LLC

40. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

41. SHARKNINJA MANAGEMENT LLC at all relevant times designed, manufactured,

assembled, tested, inspected, distributed, marketed and/or sold the subject blender. 

42. SHARKNINJA MANAGEMENT LLC impliedly warranted that the subject blender

was merchantable, fit for the ordinary purpose for which it was sold or used, was of fair average 

quality as to pass without objection in the trade, and conformed to SHARKNINJA MANAGEMENT 

LLC’s own affirmations regarding the subject blender’s safety features and overall safe condition.

43. SHARKNINJA MANAGEMENT LLC breached their implied warranty of 

merchantability, as the product did not conform to SHARKNINJA MANAGEMENT LLC’s 

affirmations regarding the safety features and overall safe condition of the subject blender, the subject 

blender was not fit for the ordinary purpose for which it was sold or used, and/or was not of fair 

average quality so as to pass without objection in the trade.

44. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

the implied warranty of merchantability, the subject blender suddenly and without warning disgorged 

its sharp and dangerous blade, which lacked adequate support to hold it, causing LORENZO’s

incident and serious injuries. 

45. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

the implied warranty of merchantability, LORENZO suffered bodily injury and resulting pain and 

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

expense of hospitalization, medical and nursing care and treatment, rehabilitative expenses, and

inconvenience. The losses are permanent and continuing in nature and LORENZO will suffer these 

losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT V

BREACH OF IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR

PURPOSE AGAINST SHARKNINJA MANAGEMENT LLC

46. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

47. SHARKNINJA MANAGEMENT LLC designed, manufactured, assembled, tested, 

inspected, distributed, marketed and/or sold the subject blender. 

48. In selling the subject blender to LORENZO, SHARKNINJA MANAGEMENT LLC, 

through its agents, servants, employees, and apparent agents, acting within the scope of their

employment, authority, or apparent authority, made representations and promotions concerning the 

particular purpose to which LORENZO would put the subject blender to use and knew or should have 

known of the particular purpose to which LORENZO would put the product to use. SHARKNINJA 

MANAGEMENT LLC impliedly warranted that the product would be fit for such particular purpose.

49. SHARKNINJA MANAGEMENT LLC breached its implied warranty of fitness for a 

particular purpose, as the subject blender did not conform to SHARKNINJA MANAGEMENT 

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LLC’s affirmations regarding its product being fit for such particular purpose. The subject blender’s 

malfunctioning safety features and overall unsafe condition rendered it unfit for that purpose.

50. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

the implied warranty of fitness for a particular purpose, the subject blender suddenly and without 

warning disgorged its sharp and dangerous blade, which lacked adequate support to hold it, causing 

LORENZO’s incident and serious injuries. 

51. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

the implied warranty of fitness for a particular purpose, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT VI

FAILURE TO WARN AGAINST SHARKNINJA MANAGEMENT LLC

52. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

53. SHARKNINJA MANAGEMENT LLC designed, manufactured, assembled, tested, 

inspected, distributed, marketed and/or sold the subject blender. 

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54. On or about November 3, 2019, LORENZO used the subject blender in the manner

intended and/or foreseeably intended, when the subject blender failed and/or otherwise caused injury 

to LORENZO. 

55. The subject blender was manufactured in a defective manner, was defectively designed, 

failed to have adequate and proper warnings or instructions, was not safe to be used for the purposes 

intended, and/or was otherwise inherently and/or unreasonably dangerous.

56. SHARKNINJA MANAGEMENT LLC knew or should have known of the dangerous 

nature of the subject blender by virtue of its business, and/or knew or should have known of the need 

to provide adequate warnings concerning the use of the subject blender. For example, SHARKNINJA 

MANAGEMENT LLC has previously been sued in this circuit, district, and throughout this nation 

for similar malfunctions. See Wallace et al. v. Sharkninja Operating LLC, Case 5:18-cv-05221-BLF; 

see also Warner v. Sharkninja Operating LLC, Case 3:22-cv-00310-JCS; see also Mawla, et al. v. 

Sharkninja Operating, LLC, Case 3:21-cv-05202-JD; see also Moberly v. Sharkninja Operating LLC, 

et al., Case 2:22-cv-14259-AMC; see also Gallo, et al., v. BJ’S WHOLESALE CLUB, INC., et al., 

Case 1:20-cv-22907-CMA.

57. SHARKNINJA MANAGEMENT LLC had a duty to provide reasonable warnings of 

dangers involved in the use of the subject blender, and failed to provide the public, including

LORENZO, notice of the danger involved.

58. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s failure to 

warn of the dangers of the subject blender, LORENZO was unable to protect herself or otherwise 

avoid injury when her incident occurred. 

59. As a direct and proximate result of the foregoing, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

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enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT I 

STRICT LIABILITY CLAIM AGAINST SHARKNINJA OPERATING LLC

60. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

61. The subject blender was defective and unreasonably dangerous by virtue of its condition

and the failure to warn of known and foreseeable risks, insofar as it was subject to disgorgement of 

its sharp and dangerous blade suddenly and unexpectedly in the course of foreseeable use, and insofar 

as the subject blender had no support to hold the blade. 

62. The subject defect existed at the time it left the possession and control of SHARKNINJA 

OPERATING LLC, and, at the time it came into the possession of LORENZO. 

63. The subject blender had not been altered and/or damaged prior to the time of the incident 

described herein and was in substantially the same condition at the time of the incident described as 

at the time it was manufactured and sold by SHARKNINJA OPERATING LLC and placed in the 

stream of commerce.

64. At all relevant times, SHARKNINJA OPERATING LLC was in the business of 

designing, manufacturing, inspecting, testing, distributing, selling and/or marketing blenders and did 

design, manufacture, inspect, test, distribute, sell and/or market the subject blender. 

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65. The subject blender failed to perform in a manner reasonably expected in light of its 

nature and intended function when it failed and caused severe injuries.

66. The subject blender had not been misused post-sale before it failed.

67. The subject blender was within its anticipated useful life when it failed.

68. The subject blender’s failure was such that would not have occurred in the absence of a 

defect or unreasonably dangerous condition within it.

69. Specifically, the subject blender was unreasonably dangerous and/or defective in that:

a. it was dangerous to an extent beyond that which would be contemplated by the 

ordinary consumer who purchases and/or uses it, with the ordinary knowledge

common to the community as to its characteristics; and/or

b. a reasonably prudent manufacturer would not have put it on the market assuming 

that manufacturer knew of its dangerous condition.

70. As a direct and proximate result of the defective and unreasonably dangerous conditions 

of the subject blender, it suddenly and without warning disgorged its sharp and dangerous blade,

which lacked adequate support to hold it, causing LORENZO’s incident and serious injuries. 

71. As a direct and proximate result of the defective and unreasonably dangerous condition 

of the subject blender and the resulting incident as described, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

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Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT II 

NEGLGIENCE CLAIM AGAINST SHARKNINJA OPERATING LLC

72. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

73. At all times material SHARKNINJA OPERATING LLC had a duty to LORENZO to 

exercise reasonable care in the design, testing and manufacture of the subject blender as described in 

the incident above.

74. SHARKNINJA OPERATING LLC knew, or in the existence of ordinary care, should 

have known, that the subject blender was defective and unreasonably dangerous to those persons 

likely to use the product for the purpose and in the manner for which it was intended to be used. For 

example, SHARKNINJA OPERATING LLC has previously been sued in this circuit, district, and 

throughout this nation for similar malfunctions. See Wallace et al. v. Sharkninja Operating LLC, Case 

5:18-cv-05221-BLF; see also Warner v. Sharkninja Operating LLC, Case 3:22-cv-00310-JCS; see 

also Mawla, et al. v. Sharkninja Operating, LLC, Case 3:21-cv-05202-JD; see also Moberly v. 

Sharkninja Operating LLC, et al., Case 2:22-cv-14259-AMC; see also Gallo, et al., v. BJ’S 

WHOLESALE CLUB, INC., et al., Case 1:20-cv-22907-CMA.

75. Alternatively, SHARKNINJA OPERATING LLC knew, or in the exercise of ordinary 

care should have known, of the means of designing, manufacturing and/or marketing the subject 

blender such that the type of incident and resulting injuries and damages as described herein would 

have been prevented.

76. Alternatively, SHARKNINJA OPERATING LLC had actual or constructive knowledge 

of the means of designing a blender that would not be inadequate and dangerous, and notwithstanding 

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this knowledge, SHARKNINJA OPERATING LLC failed to adequately design, equip and/or 

manufacture the subject blender. 

77. Alternatively, SHARKNINJA OPERATING LLC negligently failed to give adequate 

warnings or instructions, and/or failed to make appropriate post-marketing efforts to prevent known 

incidents, such as the one included herein.

78. Alternatively, SHARKNINJA OPERATING LLC failed to adequately design, 

manufacture, test, inspect, market and/or sell the subject blender, and/or failed to include a reasonable 

and safer alternative to the subject defective condition.

79. Alternatively, SHARKNINJA OPERATING LLC failed to adequately monitor 

consumer injury and damage reports associated with the subject blender, and/or failed to include a

reasonable and safer alternatives to the subject defective condition.

80. As a direct and proximate result of SHARKNINJA OPERATING LLC’s negligence, the 

subject blender suddenly and without warning disgorged its sharp and dangerous blade, which lacked

adequate support to hold it, causing LORENZO’s incident and serious injuries. 

81. As a direct and proximate result of SHARKNINJA OPERATING LLC’s negligence, 

LORENZO suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental 

anguish, loss of capacity for the enjoyment of life, the expense of hospitalization, medical and nursing 

care and treatment, rehabilitative expenses, and inconvenience. The losses are permanent and 

continuing in nature and LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

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COUNT III

BREACH OF EXPRESS WARRANTY AGAINST SHARKNINJA OPERATING LLC

82. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

83. SHARKNINJA OPERATING LLC designed, manufactured, assembled, distributed,

inspected, tested and/or sold the subject blender. 

84. SHARKNINJA OPERATING LLC expressly warranted that the subject blender was 

safe for ordinary use when used in compliance with the instructions provided, which LORENZO 

followed.

85. SHARKNINJA OPERATING LLC’s affirmations regarding the safety of its product 

formed a basis of the bargain for LORENZO without which LORENZO would not have purchased 

and/or used the subject blender. 

86. The subject blender did not conform to SHARKNINJA OPERATING LLC’s 

affirmations regarding safety.

87. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of 

express warranties, the subject blender suddenly and without warning disgorged its sharp and 

dangerous blade, which lacked adequate support to hold it, causing LORENZO’s incident and serious 

injuries. 

88. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of 

express warranties, LORENZO suffered bodily injury and resulting pain and suffering, disability, 

disfigurement, mental anguish, loss of capacity for the enjoyment of life, the expense of 

hospitalization, medical and nursing care and treatment, rehabilitative expenses, and inconvenience. 

The losses are permanent and continuing in nature and LORENZO will suffer these losses in the 

future.

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WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT IV

BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY AGAINST

SHARKNINJA OPERATING LLC

89. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

90. SHARKNINJA OPERATING LLC at all relevant times designed, manufactured,

assembled, tested, inspected, distributed, marketed and/or sold the subject blender. 

91. SHARKNINJA OPERATING LLC impliedly warranted that the subject blender was

merchantable, fit for the ordinary purpose for which it was sold or used, was of fair average quality 

as to pass without objection in the trade, and conformed to SHARKNINJA OPERATING LLC’s own 

affirmations regarding the subject blender’s safety features and overall safe condition.

92. SHARKNINJA OPERATING LLC breached their implied warranty of merchantability, 

as the product did not conform to SHARKNINJA OPERATING LLC’s affirmations regarding the 

safety features and overall safe condition of the subject blender, the subject blender was not fit for the

ordinary purpose for which it was sold or used, and/or was not of fair average quality so as to pass 

without objection in the trade.

93. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of the 

implied warranty of merchantability, the subject blender suddenly and without warning disgorged its 

sharp and dangerous blade, which lacked adequate support to hold it, causing LORENZO’s incident

and serious injuries. 

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94. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of the 

implied warranty of merchantability, LORENZO suffered bodily injury and resulting pain and 

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

expense of hospitalization, medical and nursing care and treatment, rehabilitative expenses, and

inconvenience. The losses are permanent and continuing in nature and LORENZO will suffer these 

losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT V

BREACH OF IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR

PURPOSE AGAINST SHARKNINJA OPERATING LLC

95. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

96. SHARKNINJA OPERATING LLC designed, manufactured, assembled, tested, 

inspected, distributed, marketed and/or sold the subject blender. 

97. In selling the subject blender to LORENZO, SHARKNINJA OPERATING LLC, 

through its agents, servants, employees, and apparent agents, acting within the scope of their

employment, authority, or apparent authority, made representations and promotions concerning the 

particular purpose to which LORENZO would put the subject blender to use and knew or should have 

known of the particular purpose to which LORENZO would put the product to use. SHARKNINJA 

OPERATING LLC impliedly warranted that the product would be fit for such particular purpose.

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98. SHARKNINJA OPERATING LLC breached its implied warranty of fitness for a 

particular purpose, as the subject blender did not conform to SHARKNINJA OPERATING LLC’s

affirmations regarding its product being fit for such particular purpose. The subject blender’s 

malfunctioning safety features and overall unsafe condition rendered it unfit for that purpose.

99. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of the 

implied warranty of fitness for a particular purpose, the subject blender suddenly and without warning 

disgorged its sharp and dangerous blade, which lacked adequate support to hold it, causing 

LORENZO’s incident and serious injuries. 

100. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of the 

implied warranty of fitness for a particular purpose, LORENZO suffered bodily injury and resulting 

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

life, the expense of hospitalization, medical and nursing care and treatment, rehabilitative expenses, 

and inconvenience. The losses are permanent and continuing in nature and LORENZO will suffer 

these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT VI

FAILURE TO WARN AGAINST SHARKNINJA OPERATING LLC

101. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

102. SHARKNINJA OPERATING LLC designed, manufactured, assembled, tested, 

inspected, distributed, marketed and/or sold the subject blender. 

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 37 of 86
ARONFELD TRIAL LAWYERS

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Page 20 of 21 

103. On or about November 3, 2019, LORENZO used the subject blender in the manner

intended and/or foreseeably intended, when the subject blender failed and/or otherwise caused injury 

to LORENZO. 

104. The subject blender was manufactured in a defective manner, was defectively designed, 

failed to have adequate and proper warnings or instructions, was not safe to be used for the purposes 

intended, and/or was otherwise inherently and/or unreasonably dangerous.

105. SHARKNINJA OPERATING LLCknew or should have known of the dangerous nature 

of the subject blender by virtue of its business, and/or knew or should have known of the need to 

provide adequate warnings concerning the use of the subject blender. For example, SHARKNINJA 

OPERATING LLC has previously been sued in this circuit, district, and throughout this nation for 

similar malfunctions. See Wallace et al. v. Sharkninja Operating LLC, Case 5:18-cv-05221-BLF; see 

also Warner v. Sharkninja Operating LLC, Case 3:22-cv-00310-JCS; see also Mawla, et al. v. 

Sharkninja Operating, LLC, Case 3:21-cv-05202-JD; see also Moberly v. Sharkninja Operating LLC, 

et al., Case 2:22-cv-14259-AMC; see also Gallo, et al., v. BJ’S WHOLESALE CLUB, INC., et al., 

Case 1:20-cv-22907-CMA.

106. SHARKNINJA OPERATING LLC had a duty to provide reasonable warnings of 

dangers involved in the use of the subject blender, and failed to provide the public, including

LORENZO, notice of the danger involved.

107. As a direct and proximate result of SHARKNINJA OPERATING LLC’s failure to warn 

of the dangers of the subject blender, LORENZO was unable to protect herself or otherwise avoid 

injury when her incident occurred. 

108. As a direct and proximate result of the foregoing, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 38 of 86
ARONFELD TRIAL LAWYERS

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Page 21 of 21 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

DEMAND FOR JURY TRIAL

Plaintiff, RACHEL LORENZO, demands trial by jury on all issues so triable. 

Dated: September 8, 2022. 

Respectfully submitted,

/s/ Matthias M. Hayashi 

Spencer M. Aronfeld, Esq.

Florida Bar No.: 905161

aronfeld@Aronfeld.com 

Abby H. Ivey, Esq.

Florida Bar No.: 1002774 

aivey@aronfeld.com

Matthias M. Hayashi

Florida Bar No.: 115973

mhayashi@aronfeld.com

ARONFELD TRIAL LAWYERS

One Alhambra Plaza, Penthouse 

Coral Gables, Florida 33134 

P: (305) 441.0440 

F: (305) 441.0198 

Attorneys for LORENZO

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 39 of 86
- 3 -

EXHIBIT C

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 40 of 86
JS 44 (Rev. 10/20) FLSD Revised 02/12/2021 CIVIL COVER SHEET

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided 

by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating 

the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.

I. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF

THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

(d)Check County Where Action Arose: MIAMI- DADE MONROE BROWARD PALM BEACH MARTIN ST. LUCIE INDIAN RIVER OKEECHOBEE HIGHLANDS

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff)

(For Diversity Cases Only) and One Box for Defendant)

1 U.S. Government 3 Federal Question PTF DEF PTF DEF

Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4

of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5

Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

 Foreign Country

IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions

CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act

120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC

130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729 (a))

140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment

150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust

& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking

151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce

152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent – Abbreviated New Drug Application 460 Deportation

Student Loans 340 Marine

840 Trademark

880 Defend Trade Secrets

 Act of 2016

470 Racketeer Influenced and 

Corrupt Organizations

(Excl. Veterans) 345 Marine Product LABOR SOCIAL SECURITY 480 Consumer Credit 

 (15 USC 1681 or 1692)

153 Recovery of Overpayment Liability

 Injury Product Liability

710 Fair Labor Standards 861 HIA (1395ff) 485 Telephone Consumer 

Protection Act (TCPA)

of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) 490 Cable/Sat TV

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Mgmt. Relations 863 DIWC/DIWW (405(g)) 850 Securities/Commodities/

190 Other Contract Product Liability 380 Other Personal 740 Railway Labor Act 864 SSID Title XVI Exchange

195 Contract Product Liability 360 Other Personal Property Damage 751 Family and Medical 865 RSI (405(g)) 890 Other Statutory Actions

196 Franchise Injury 385 Property Damage Leave Act 891 Agricultural Acts

362 Personal Injury - Product Liability 790 Other Labor Litigation 893 Environmental Matters

Med. Malpractice 791 Empl. Ret. Inc. 895 Freedom of Information

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS Security Act FEDERAL TAX SUITS Act

210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 870 Taxes (U.S. Plaintiff 896 Arbitration

220 Foreclosure 441 Voting 463 Alien Detainee or Defendant) 899 Administrative Procedure

230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 

Sentence

871 IRS—Third Party 26 USC 

7609 Act/Review or Appeal of Agency Decision

240 Torts to Land 443 Housing/

Accommodations Other: 950 Constitutionality of State Statutes

245 Tort Product Liability 445 Amer. w/Disabilities - 530 General IMMIGRATION

290 All Other Real Property Employment 535 Death Penalty 462 Naturalization Application 

446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration

Other 550 Civil Rights Actions

448 Education 555 Prison Condition

560 Civil Detainee – Conditions of 

Confinement

V. ORIGIN (Place an “X” in One Box Only)

Transferred from

another district

(specify)

6 Multidistrict

Litigation

Transfer

8 Multidistrict 

Litigation 

– Direct 

File

9 Remanded from 

Appellate Court 

1 Original

Proceeding

2 Removed 

from State 

Court 

3 Re-filed 

(See VI 

below)

4 Reinstated 

or

Reopened

5 7 Appeal to 

District Judge 

from Magistrate

Judgment

VI. RELATED/

RE-FILED CASE(S)

(See instructions): a) Re-filed Case YES NO b) Related Cases YES NO

JUDGE: DOCKET NUMBER:

VII. CAUSE OF ACTION

Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity):

LENGTH OF TRIAL via days estimated (for both sides to try entire case)

VIII. REQUESTED IN

COMPLAINT:

CHECK IF THIS IS A CLASS ACTION

UNDER F.R.C.P. 23 DEMAND $ CHECK YES only if demanded in complaint:

JURY DEMAND: Yes No

ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE

DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY : RECEIPT # AMOUNT IFP JUDGE MAG JUDGE

PERSONAL PROPERTY

 SharkNinja Management LLC and

 SharkNinja Operating LLC 

 Norfolk 

 X

 

 

 Spencer Aronfeld, Abby H. Ivey, Mathias M. Hayashi, Riana S. Maryanoff, Aronfeld Trial

 Lawyers, One Alhambra Plaza Penthouse Coral Gables, FL 33134, (305) 441.0440

Scott D. Kaiser, Shook, Hardy & Bacon LLP, 2555 Grand Blvd, Kansas City, MO 64108

(816) 474-6550

 X 

 X

 X

 X X

29 U.S.C. Sections 1332, 1441, and 1446. Plaintiff asserts a product-liability action. Plaintiff's citizenship is diverse from the Defendants. 

7

 X

September 26, 2022 /s/ Scott D. Kaiser

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 41 of 86
- 4 -

EXHIBIT D

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 42 of 86
V> co‘'»>i

'% MIAMI-DADE COUNTY CLERK OF THE COURTS , % z. HARVEY RUVIN h: ' . ZStc

Contact Us Mv Account

CIVIL, FAMILY AND PROBATE COURTS ONLINE SYSTEM

^ BACK

Not all search results will be displayed on-line. For example, the following case types (Sealed, Juvenile, Adoption and Mental Health Cases) may or

may not be in existence and may or may not be viewable by the public pursuant to Florida Supreme Court Mandate and the corresponding Access

Security MatrixRACHEL LORENZO VS SHARKNINJA MANAGEMENT LLC ET AL

Local Case Number: 2022-014612-CA-01 Filing Date: 08/02/2022

State Case Number: 132022CA014612000001 Judicial Section: CA23

Consolidated Case No.: N/A Case Type: Product Liability

Case Status: OPEN

V Parties Total Of Parties: 3 TM

Party Description Party Name Attorney Information Other Attorney(S)

Plaintiff Lorenzo, Rachel

Defendant SHARKNINJA MANAGEMENT LLC

Defendant SHARKNINJA OPERATING LLC

^ Hearing Details Total Of Hearings: 0 —

Hearing Date Hearing Time Hearing Code Description Hearing Location

Dockets Total Of Dockets: 9 “

Docket

Book/Page Entry

Event

Number Date Type Comments

9 09/15/2022 Service

Returned

Event SHARKNINJA MANAGEMENT.LLC.

Amended Event

Complaint

8 09/08/2022

08/23/2022 20 Day Service

Summons

Issued

7 08/23/2022 ESummons Event RE: INDEX # 5.

20 Day Parties: SHARKNINJA MANAGEMENT LLC

Issued

RECEIPT#:3050032 AMT PAID:$10.00 COMMENT: ALLOCATION CODE

QUANTITY UNIT AMOUNT 3139-SUMMONS ISSUE FEE 1 $10.00 $10.00

TENDER TYPE:EFILINGS TENDER AMT:$10.00 RECEIPT DATE:08/19/2022

6 08/19/2022 Receipt: Event

1/3

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 43 of 86
REGISTER#:305 CASHIER:EFILINGUSER Docket

Book/Page Entry

Event

Number Date Type Comments

5 08/10/2022 (M) 20 Day Event

(C)

Summons

(Sub)

Received

RECEIPT#:3070081 AMT PAID:$401.00 COMMENT: ALLOCATION CODE

QUANTITY UNIT AMOUNT 3100-CIRCUIT FILING FEE 1 $401.00 $401.00

TENDER TYPE:EFILINGS TENDER AMT:$401.00 RECEIPT DATE:08/10/2022

REGISTER#:307 CASHIERiEFILINGUSER

4 08/10/2022 Receipt: Event

2 08/02/2022 Complaint Event

Civil Cover Event

Sheet -

Claim

Amount

1 08/02/2022

«BACK

Please be advised:

The Clerk's Office makes every effort to ensure the accuracy of the following information; however it makes no warranties or representations whatsoever regarding the

completeness, accuracy, or timeliness of such information and data. Information on this website has been posted with the intent that it be readily available for personal

and public non-commercial (educational) use and to provide the public with direct online access to information in the Miami-Dade Clerk's Office information systems.

Other than making limited copies ofthis website's content, you may not reproduce, retransmit, redistribute, upload or post any part of this website, including the

contents thereof, in any form or by any means, or store it in any information storage and retrieval system, without prior written permission from the Miami-Dade Clerk's

Office.

If you are interested in obtaining permission to reproduce, retransmit or store any part of this website beyond that which you may use for personal use, as defined

above, visit our Web API Services. You can review the complete Miami-Dade County Disclaimer

General

Online Case Home

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Help and Support

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m

WilFI

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V

Is? cexM5l s;

HARVEY RUVIN Miami-Dade County

Clerk of the Courts

73 W Flanlpr ^trPPt 2/3

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 44 of 86
Miami, Florida 33130

305-275-1155

©2022 Clerk of the Courts. All rights reserved.

MIAMI

3/3

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 45 of 86
- 5 -

EXHIBIT E

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 46 of 86
Filing # 154552748 E-Filed 08/02/2022 05:15:04 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 ofpleadings or other documents as required by law. This form must be filed by the

plaintiff or petitioner with the Clerk ofCourt for the purpose ofreporting uniform data pursuant

to section 25.075, Florida Statutes. (See instructions for completion.)

I. CASE STYLE

IN THE CIRCUIT/COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT,

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

Rachel Lorenzo

Plaintiff Case #

Judge

vs.

SHARKNINJA MANAGEMENT LLC

Defendant

II. AMOUNT OF CLAIM

Please indicate the estimated amount ofthe claim, rounded to the nearest dollar. The estimated amount of

the claim is requested for data collection and clerical processing purposes only. The amount ofthe claim

shall not be used for any other purpose.

□ $8,000 or less

$8,001 $30,000

M $30,001- $50,000

$50,001-$75,000

□ $75,001 - $100,000

□ over $100,000.00

III. TYPE OF CASE (Ifthe case fits more than one type of case, select the most

definitive category.) Ifthe most descriptive label is a subcategory (is indented under a broader

category), place an x on both the main category and subcategory lines.

- 1 -

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 47 of 86
REGISTER#:305 CASHIER:EFILINGUSER Docket

Book/Page Entry

Event

Number Date Type Comments

5 08/10/2022 (M) 20 Day Event

(C)

Summons

(Sub)

Received

RECEIPT#:3070081 AMT PAID:$401.00 COMMENT: ALLOCATION CODE

QUANTITY UNIT AMOUNT 3100-CIRCUIT FILING FEE 1 $401.00 $401.00

TENDER TYPE:EFILINGS TENDER AMT:$401.00 RECEIPT DATE:08/10/2022

REGISTER#:307 CASHIERiEFILINGUSER

4 08/10/2022 Receipt: Event

2 08/02/2022 Complaint Event

Civil Cover Event

Sheet -

Claim

Amount

1 08/02/2022

«BACK

Please be advised:

The Clerk's Office makes every effort to ensure the accuracy of the following information; however it makes no warranties or representations whatsoever regarding the

completeness, accuracy, or timeliness of such information and data. Information on this website has been posted with the intent that it be readily available for personal

and public non-commercial (educational) use and to provide the public with direct online access to information in the Miami-Dade Clerk's Office information systems.

Other than making limited copies ofthis website's content, you may not reproduce, retransmit, redistribute, upload or post any part of this website, including the

contents thereof, in any form or by any means, or store it in any information storage and retrieval system, without prior written permission from the Miami-Dade Clerk's

Office.

If you are interested in obtaining permission to reproduce, retransmit or store any part of this website beyond that which you may use for personal use, as defined

above, visit our Web API Services. You can review the complete Miami-Dade County Disclaimer

General

Online Case Home

Civil / Family Courts Information

Login

Help and Support

Clerk's Home

Privacy Statement

ADA Notice

m

WilFI

About Us

V

Is? cexM5l s;

HARVEY RUVIN Miami-Dade County

Clerk of the Courts

73 W Flanlpr ^trPPt 2/3

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 48 of 86
Miami, Florida 33130

305-275-1155

©2022 Clerk of the Courts. All rights reserved.

MIAMI

3/3

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 49 of 86
CIRCUIT CIVIL

□ Condominium

□ Contracts and indebtedness

□ Eminent domain

□ Auto negligence

□ Negligence—other

□ Business governance

□ Business torts

□ Environmental/Toxic tort

□ Third party indemnification

□ Construction defect

□ Mass tort

□ Negligent security

□ Nursing home negligence

□ Premises liability—commercial

□ Premises liability—^residential

1X1 Products liability

□ Real Property/Mortgage foreclosure

□ Commercial foreclosure

□ Homestead residential foreclosure

□ Non-homestead residential foreclosure

□ Other real property actions

□Professional malpractice

□ Malpractice—^business

□ Malpractice—medical

□ Malpractice—other professional

□ Other

□ Antitrust/Trade regulation

□ Business transactions

□ Constitutional challenge—statute or ordinance

□ Constitutional challenge—^proposed amendment

□ Corporate trusts

□ Discrimination—employment or other

□ Insurance claims

□ Intellectual property

□ Libel/Slander

□ Shareholder derivative action

□ Securities litigation

□ Trade secrets

□ Trust litigation

COUNTY CIVIL

□ Small Claims up to $8,000

□ Civil

□ Real property/Mortgage foreclosure

-2-

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 50 of 86
□ Replevins

□ Evictions

□ Residential Evictions

□ Non-residential Evictions

□ Other civil (non-monetary)

COMPLEX BUSINESS COURT

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

Administrative Order. Yes □ No IE

IV. REMEDIES SOUGHT (check all that apply):

IXI Monetary;

□ Nonmonetary declaratory or injunctive relief;

□ Punitive

V. NUMBER OF CAUSES OF ACTION: [ ]

(Specify)

6

VI. IS THIS CASE A CLASS ACTION LAWSUIT?

□ yes

Kl no

HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?

IE no

□ yes If “yes,” list all related cases by name, case number, and court.

VII.

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT?

IE yes

□ no

DOES THIS CASE INVOLVE ALLEGATIONS OF SEXUAL ABUSE?

□ yes

IE no

IX.

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 ofJudicial Administration 2.425.

Signature: s/ Abbv Hernandez Ivey

Attorney or party

Fla. Bar# 1002774

(Bar # ifattorney)

Abbv Hernandez Ivey 08/09/2022

(type or print name) Date

-3-

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 51 of 86
ARONFELD TRIAL LAWYERS 

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Page 1 of 11

IN THE CIRCUIT COURT FOR THE 

ELEVENTH JUDICIAL CIRCUIT IN AND 

FOR MIAMI-DADE COUNTY, FLORIDA 

CASE NO. 

GENERAL JURISDICTION DIVISION 

RACHEL LORENZO, 

Plaintiff, 

v.

SHARKNINJA MANAGEMENT LLC, 

Defendant. 

________________________________/ 

COMPLAINT FOR DAMAGES 

AND DEMAND FOR TRIAL BY JURY 

Plaintiff, RACHEL LORENZO (hereinafter “LORENZO”), through undersigned counsel, 

sues Defendant, SHARKNINJA MANAGEMENT LLC, (hereinafter “SHARKNINJA”), and 

demands trial by jury, stating as follows: 

PARTIES AND JURISDICTION 

1. LORENZO seeks damages in excess of Thirty Thousand Dollars ($30,000.00),

exclusive of interest, costs, and attorneys’ fees. 

2. LORENZO was and is at all times a citizen and resident of Miami-Dade County,

Florida. 

3. LORENZO sustained serious and permanent injuries in an incident which occurred

on November 3, 2019 in Miami-Dade County, Florida. 

4. SHARKNINJA was at all times material a foreign corporation authorized to do business

and doing business in the state of Florida, engaged in the business of designing, testing, fabricating, 

Filing # 154552748 E-Filed 08/02/2022 05:15:04 PM Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 52 of 86
ARONFELD TRIAL LAWYERS 

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Page 2 of 11

manufacturing, assembling, producing, distributing and selling home kitchen appliances, including 

the Ninja Master blender model QB900B (hereinafter the “subject blender”). 

5. At all times material, the subject blender was in substantially the same condition as when

it left the respective manufacturer’s and consumer seller’s possession, and there were no changes 

made to the subject blender between the time it left SHARKNINJA’ possession and the time of the 

subject incident. 

6. On November 3, 2019, LORENZO was operating the subject blender when it suddenly

and unexpectedly disgorged its blade, which sliced through her right foot, toes, and/or tendons. 

Furthermore, the subject blender had no support to hold the blade. 

7. The defects inherent in the subject blender were not reasonably discoverable by

LORENZO and were unknown to her at the time and place of the incident. 

8. As a result, LORENZO sustained serious and permanent injuries.

COUNT I 

STRICT LIABILITY CLAIM AGAINST SHARKNINJA

9. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein.

10. The subject blender was defective and unreasonably dangerous by virtue of its condition

and the failure to warn of known and foreseeable risks, insofar as it was subject to disgorgement of 

its sharp and dangerous blade suddenly and unexpectedly in the course of foreseeable use, and insofar 

as the subject blender had no support to hold the blade 

11. The subject defect existed at the time it left the possession and control of

SHARKNINJA, and, at the time it came into the possession of LORENZO. 

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 53 of 86
ARONFELD TRIAL LAWYERS 

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Page 3 of 11

12. The subject blender had not been altered and/or damaged prior to the time of the incident

described herein and was in substantially the same condition at the time of the incident described as 

at the time it was manufactured and sold by SHARKNINJA and placed in the stream of commerce. 

13. At all relevant times, SHARKNINJA was in the business of designing, manufacturing,

inspecting, testing, distributing, selling and/or marketing blenders and did design, manufacture, 

inspect, test, distribute, sell and/or market the subject blender. 

14. The subject blender failed to perform in a manner reasonably expected in light of its

nature and intended function when it failed and caused severe injuries. 

15. The subject blender had not been misused post-sale before it failed.

16. The subject blender was within its anticipated useful life when it failed.

17. The subject blender’s failure was such that would not have occurred in the absence of a

defect or unreasonably dangerous condition within it. 

18. Specifically, the subject blender was unreasonably dangerous and/or defective in that:

a. it was dangerous to an extent beyond that which would be contemplated by the

ordinary consumer who purchases and/or uses it, with the ordinary knowledge 

common to the community as to its characteristics; and/or 

b. a reasonably prudent manufacturer would not have put it on the market assuming

that manufacturer knew of its dangerous condition. 

19. As a direct and proximate result of the defective and unreasonably dangerous conditions

of the subject blender, it suddenly and without warning disgorged its sharp and dangerous blade, 

which lacked adequate support to hold it, causing LORENZO’s incident and serious injuries. 

20. As a direct and proximate result of the defective and unreasonably dangerous condition

of the subject blender and the resulting incident as described, LORENZO suffered bodily injury and 

Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 54 of 86
ARONFELD TRIAL LAWYERS 

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Page 4 of 11

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future. 

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against 

Defendant, SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in 

excess of Thirty Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues

triable as of right by a jury. 

COUNT II 

NEGLGIENCE CLAIM AGAINST SHARKNINJA 

21. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein. 

22. At all times material SHARKNINJA had a duty to LORENZO to exercise reasonable

care in the design, testing and manufacture of the subject blender as described in the incident above. 

23. SHARKNINJA knew, or in the existence of ordinary care, should have known, that the

subject blender was defective and unreasonably dangerous to those persons likely to use the product 

for the purpose and in the manner for which it was intended to be used. For example, SHARKNINJA 

has previously been sued in this circuit, district, and throughout this nation for similar malfunctions. 

See Wallace et al. v. Sharkninja Operating LLC, Case 5:18-cv-05221-BLF; see also Warner v. 

Sharkninja Operating LLC, Case 3:22-cv-00310-JCS; see also Mawla, et al. v. Sharkninja Operating, 

LLC, Case 3:21-cv-05202-JD; see also Moberly v. Sharkninja Operating LLC, et al., Case 2:22-cv14259-AMC; see also Gallo, et al., v. BJ’S WHOLESALE CLUB, INC., et al., Case 1:20-cv-22907-

CMA. 

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24. Alternatively, SHARKNINJA knew, or in the exercise of ordinary care should have 

known, of the means of designing, manufacturing and/or marketing the subject blender such that the 

type of incident and resulting injuries and damages as described herein would have been prevented. 

25. Alternatively, SHARKNINJA had actual or constructive knowledge of the means of 

designing a blender that would not be inadequate and dangerous, and notwithstanding this knowledge, 

SHARKNINJA failed to adequately design, equip and/or manufacture the subject blender. 

26. Alternatively, SHARKNINJA negligently failed to give adequate warnings or 

instructions, and/or failed to make appropriate post-marketing efforts to prevent known incidents, 

such as the one included herein. 

27. Alternatively, SHARKNINJA failed to adequately design, manufacture, test, inspect, 

market and/or sell the subject blender, and/or failed to include a reasonable and safer alternative to 

the subject defective condition. 

28. Alternatively, SHARKNINJA failed to adequately monitor consumer injury and damage 

reports associated with the subject blender, and/or failed to include a reasonable and safer alternatives 

to the subject defective condition. 

29. As a direct and proximate result of SHARKNINJA’s negligence, the subject blender 

suddenly and without warning disgorged its sharp and dangerous blade, which lacked adequate 

support to hold it, causing LORENZO’s incident and serious injuries. 

30. As a direct and proximate result of SHARKNINJA’s negligence, LORENZO suffered 

bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of 

capacity for the enjoyment of life, the expense of hospitalization, medical and nursing care and 

treatment, rehabilitative expenses, and inconvenience. The losses are permanent and continuing in 

nature and LORENZO will suffer these losses in the future. 

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WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Thirty

Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues triable as of right by a 

jury. 

COUNT III

BREACH OF EXPRESS WARRANTY AGAINST SHARKNINJA

31. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein. 

32. SHARKNINJA designed, manufactured, assembled, distributed, inspected, tested

and/or sold the subject blender. 

33. SHARKNINJA expressly warranted that the subject blender was safe for ordinary use

when used in compliance with the instructions provided, which LORENZO followed. 

34. SHARKNINJA’s affirmations regarding the safety of its product formed a basis of the

bargain for LORENZO without which LORENZO would not have purchased and/or used the subject 

blender. 

35. The subject blender did not conform to SHARKNINJA’s affirmations regarding safety.

36. As a direct and proximate result of SHARKNINJA’s breach of express warranties, the

subject blender suddenly and without warning disgorged its sharp and dangerous blade, which lacked 

adequate support to hold it, causing LORENZO’s incident and serious injuries. 

37. As a direct and proximate result of SHARKNINJA’s breach of express warranties,

LORENZO suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental 

anguish, loss of capacity for the enjoyment of life, the expense of hospitalization, medical and nursing 

care and treatment, rehabilitative expenses, and inconvenience. The losses are permanent and 

continuing in nature and LORENZO will suffer these losses in the future. 

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WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Thirty

Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues triable as of right 

by a jury. 

COUNT IV 

BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY AGAINST 

SHARKNINJA

38. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein. 

39. SHARKNINJA at all relevant times designed, manufactured, assembled, tested,

inspected, distributed, marketed and/or sold the subject blender. 

40. SHARKNINJA impliedly warranted that the subject blender was merchantable, fit for

the ordinary purpose for which it was sold or used, was of fair average quality as to pass without 

objection in the trade, and conformed to SHARKNINJA’s own affirmations regarding the subject 

blender’s safety features and overall safe condition. 

41. SHARKNINJA breached their implied warranty of merchantability, as the product did

not conform to SHARKNINJA’s affirmations regarding the safety features and overall safe condition 

of the subject blender, the subject blender was not fit for the ordinary purpose for which it was sold 

or used, and/or was not of fair average quality so as to pass without objection in the trade. 

42. As a direct and proximate result of SHARKNINJA’s breach of the implied warranty of

merchantability, the subject blender suddenly and without warning disgorged its sharp and dangerous 

blade, which lacked adequate support to hold it, causing LORENZO’s incident and serious injuries. 

43. As a direct and proximate result of SHARKNINJA’s breach of the implied warranty of

merchantability, LORENZO suffered bodily injury and resulting pain and suffering, disability, 

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disfigurement, mental anguish, loss of capacity for the enjoyment of life, the expense of 

hospitalization, medical and nursing care and treatment, rehabilitative expenses, and inconvenience. 

The losses are permanent and continuing in nature and LORENZO will suffer these losses in the 

future. 

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Thirty

Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues triable as of right 

by a jury. 

COUNT V 

BREACH OF IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR 

PURPOSE AGAINST SHARKNINJA 

44. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein. 

45. SHARKNINJA designed, manufactured, assembled, tested, inspected, distributed,

marketed and/or sold the subject blender. 

46. In selling the subject blender to LORENZO, SHARKNINJA, through its agents,

servants, employees, and apparent agents, acting within the scope of their employment, authority, or 

apparent authority, made representations and promotions concerning the particular purpose to which 

LORENZO would put the subject blender to use and knew or should have known of the particular 

purpose to which LORENZO would put the product to use. SHARKNINJA impliedly warranted that 

the product would be fit for such particular purpose. 

47. SHARKNINJA breached its implied warranty of fitness for a particular purpose, as the

subject blender did not conform to SHARKNINJA’s affirmations regarding its product being fit for 

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such particular purpose. The subject blender’s malfunctioning safety features and overall unsafe 

condition rendered it unfit for that purpose. 

48. As a direct and proximate result of SHARKNINJA’s breach of the implied warranty of

fitness for a particular purpose, the subject blender suddenly and without warning disgorged its sharp 

and dangerous blade, which lacked adequate support to hold it, causing LORENZO’s incident and 

serious injuries. 

49. As a direct and proximate result of SHARKNINJA’s breach of the implied warranty of

fitness for a particular purpose, LORENZO suffered bodily injury and resulting pain and suffering, 

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

hospitalization, medical and nursing care and treatment, rehabilitative expenses, and 

inconvenience. The losses are permanent and continuing in nature and LORENZO will suffer 

these losses in the future. 

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against 

Defendant, SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in 

excess of Thirty Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues

triable as of right by a jury. 

COUNT VI

FAILURE TO WARN AGAINST SHARKNINJA

50. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-7 as if fully

set forth herein. 

51. SHARKNINJA designed, manufactured, assembled, tested, inspected, distributed,

marketed and/or sold the subject blender. 

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52. On or about November 3, 2019, LORENZO used the subject blender in the manner 

intended and/or foreseeably intended, when the subject blender failed and/or otherwise caused injury 

to LORENZO. 

53. The subject blender was manufactured in a defective manner, was defectively designed, 

failed to have adequate and proper warnings or instructions, was not safe to be used for the purposes 

intended, and/or was otherwise inherently and/or unreasonably dangerous. 

54. SHARKNINJA knew or should have known of the dangerous nature of the subject 

blender by virtue of its business, and/or knew or should have known of the need to provide adequate 

warnings concerning the use of the subject blender. For example, SHARKNINJA has previously been 

sued in this circuit, district, and throughout this nation for similar malfunctions. See Wallace et al. v. 

Sharkninja Operating LLC, Case 5:18-cv-05221-BLF; see also Warner v. Sharkninja Operating LLC, 

Case 3:22-cv-00310-JCS; see also Mawla, et al. v. Sharkninja Operating, LLC, Case 3:21-cv-05202-

JD; see also Moberly v. Sharkninja Operating LLC, et al., Case 2:22-cv-14259-AMC; see also Gallo, 

et al., v. BJ’S WHOLESALE CLUB, INC., et al., Case 1:20-cv-22907-CMA. 

55. SHARKNINJA had a duty to provide reasonable warnings of dangers involved in the 

use of the subject blender, and failed to provide the public, including LORENZO, notice of the danger 

involved. 

56. As a direct and proximate result of SHARKNINJA’s failure to warn of the dangers of 

the subject blender, LORENZO was unable to protect herself or otherwise avoid injury when her 

incident occurred. 

57. As a direct and proximate result of the foregoing, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

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rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature 

and LORENZO will suffer these losses in the future. 

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against 

Defendant, SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in 

excess of Thirty Thousand Dollars ($30,000.00), plus costs, and demand trial by jury of all issues

triable as of right by a jury. 

DEMAND FOR JURY TRIAL

Plaintiff, RACHEL LORENZO, demands trial by jury on all issues so triable. 

Dated: August 2, 2022. 

Respectfully submitted, 

/s/ Matthias M. Hayashi 

Spencer M. Aronfeld, Esq. 

Florida Bar No.: 905161 

aronfeld@Aronfeld.com 

Abby H. Ivey, Esq. 

Florida Bar No.: 1002774 

aivey@aronfeld.com 

Matthias M. Hayashi 

Florida Bar No.: 115973 

mhayashi@aronfeld.com 

Riana S. Maryanoff, Esq. 

Florida Bar No.: 1024768 

rmaryanoff@aronfeld.com 

ARONFELD TRIAL LAWYERS 

One Alhambra Plaza, Penthouse 

Coral Gables, Florida 33134 

P: (305) 441.0440 

F: (305) 441.0198 

Attorneys for Plaintiff 

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__________________________________________________________________________ 

__________________________________________________________________________ 

 IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. 

 IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. 

DIVISION 

 CIVIL 

 DISTRICTS 

 OTHER 

SUMMONS 20 DAY CORPORATE SERVICE 

(a) GENERAL FORMS

CASE NUMBER 

PLAINTIFF(S) VS. DEFENDANT(S) SERVICE 

THE STATE OF FLORIDA: 

To Each Sheriff of the State: 

YOU ARE COMMANDED to serve this summons and copy of the complaint or petition in this action on 

defendant(s): _______________________________________________________________ 

__________________________________________________________________________ 

__________________________________________________________________________ 

__________________________________________________________________________ 

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

Plaintiff’s Attorney: __________________________________________________________ 

CLOCK IN 

whose address is: ___________________________________________________________ 

within 20 days “ Except when suit is brought pursuant to s. 768.28, Florida Statutes, if the State of Florida, one of its agencies, 

or one of its officials or employees sued in his or her official capacity is a defendant, the time to respond shall be 40 days. 

When suit is brought pursuant to. 768.28, Florida Statutes, the time to respond shall be 30 days.” after service of this summons 

on that defendant , exclusive of the day of service, and to file the original of the defenses with the Clerk of this Clerk 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. 

HARVEY RUVIN 

CLERK of COURTS 

DEPUTY CLERK 

DATE 

AMERICANS WITH DISABILITIES ACT OF 1990 

ADA NOTICE 

“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 Aliean Simpkins, the Eleventh Judicial Circuit Court’s ADA 

Coordinator, Lawson E. Thomas Courthouse Center, 175 NW 1st Avenue, Suite 2400, 

Miami, FL 33128; Telephone (305) 349-7175; TDD (305) 349-7174, Email 

ADA@jud11.flcourts.org; or via Fax at (305) 349-7355, at least seven (7) days before your 

scheduled court appearance, or immediately upon receiving this notification if the time 

before the scheduled appearance is less than seven (7) days; if you are hearing or voice 

impaired, call 711.” 

CLK/CT. 314 Rev. 09/19 Clerk’s web address: www.miami-dadeclerk.com 

x

x

2022-014612-CA-01

RACHEL LORENZO SHARKNINJA MANAGEMENT LLC

Abby Ivey, Esq.

1 Alhambra Plaza, Penthouse

Coral Gables, FL 33134

aivey@aronfeld.com;(786) 461-8248

SharkNinja Management LLC

89 A Street Suite 100

Needham, MA 02494

Filing # 155080501 E-Filed 08/10/2022 04:23:36 PM Case 1:22-cv-23101-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 63 of 86
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

__________________________________________________________________________ 

__________________________________________________________________________ 

 IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. 

 IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. 

DIVISION 

 CIVIL 

 DISTRICTS 

 OTHER 

SUMMONS 20 DAY CORPORATE SERVICE 

(a) GENERAL FORMS

CASE NUMBER 

PLAINTIFF(S) VS. DEFENDANT(S) SERVICE 

THE STATE OF FLORIDA: 

To Each Sheriff of the State: 

YOU ARE COMMANDED to serve this summons and copy of the complaint or petition in this action on 

defendant(s): _______________________________________________________________ 

__________________________________________________________________________ 

__________________________________________________________________________ 

__________________________________________________________________________ 

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

Plaintiff’s Attorney: __________________________________________________________ 

CLOCK IN 

whose address is: ___________________________________________________________ 

within 20 days “ Except when suit is brought pursuant to s. 768.28, Florida Statutes, if the State of Florida, one of its agencies, 

or one of its officials or employees sued in his or her official capacity is a defendant, the time to respond shall be 40 days. 

When suit is brought pursuant to. 768.28, Florida Statutes, the time to respond shall be 30 days.” after service of this summons 

on that defendant , exclusive of the day of service, and to file the original of the defenses with the Clerk of this Clerk 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. 

HARVEY RUVIN 

CLERK of COURTS 

DEPUTY CLERK 

DATE 

AMERICANS WITH DISABILITIES ACT OF 1990 

ADA NOTICE 

“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 Aliean Simpkins, the Eleventh Judicial Circuit Court’s ADA 

Coordinator, Lawson E. Thomas Courthouse Center, 175 NW 1st Avenue, Suite 2400, 

Miami, FL 33128; Telephone (305) 349-7175; TDD (305) 349-7174, Email 

ADA@jud11.flcourts.org; or via Fax at (305) 349-7355, at least seven (7) days before your 

scheduled court appearance, or immediately upon receiving this notification if the time 

before the scheduled appearance is less than seven (7) days; if you are hearing or voice 

impaired, call 711.” 

CLK/CT. 314 Rev. 09/19 Clerk’s web address: www.miami-dadeclerk.com 

x

x

2022-014612-CA-01

RACHEL LORENZO SHARKNINJA MANAGEMENT LLC

Abby Ivey, Esq.

1 Alhambra Plaza, Penthouse

Coral Gables, FL 33134

aivey@aronfeld.com;(786) 461-8248

SharkNinja Management LLC

89 A Street Suite 100

Needham, MA 02494

Filing # 155080501 E-Filed 08/10/2022 04:23:36 PM

8/23/2022

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IN THE CIRCUIT COURT FOR THE 

ELEVENTH JUDICIAL CIRCUIT IN AND 

FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO. 2022-014612-CA-01 

GENERAL JURISDICTION DIVISION

RACHEL LORENZO, 

Plaintiff,

v.

SHARKNINJA MANAGEMENT LLC., 

and SHARKNINJA OPERATING LLC, 

 Defendants,

________________________________/ 

FIRST AMENDED COMPLAINT FOR DAMAGES 

AND DEMAND FOR TRIAL BY JURY

Plaintiff, RACHEL LORENZO (hereinafter “LORENZO”), through undersigned counsel, 

sues Defendants, SHARKNINJA MANAGEMENT LLC, and Defendants, SHARKNINJA 

OPERATING LLC, demands trial by jury, stating as follows:

PARTIES AND JURISDICTION

1. LORENZO seeks damages in excess of Fifteen Thousand Dollars ($15,000.00), 

exclusive of interest, costs, and attorneys’ fees.

2. LORENZO was and is at all times a citizen and resident of Miami-Dade County, 

Florida. 

3. LORENZO sustained serious and permanent injuries in an incident which occurred 

on November 3, 2019 in Miami-Dade County, Florida. 

4. SHARKNINJA MANAGEMENT LLC was at all times material a foreign corporation 

authorized to do business and doing business in the state of Florida, engaged in the business of 

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designing, testing, fabricating, manufacturing, assembling, producing, distributing and selling home 

kitchen appliances, including the Ninja Master blender model QB900B (hereinafter the “subject 

blender”).

5. SHARKNINJA OPERATING LLC was at all times material a foreign corporation 

authorized to do business and doing business in the state of Florida, engaged in the business of 

designing, testing, fabricating, manufacturing, assembling, producing, distributing and selling home 

kitchen appliances, including the Ninja Master blender model QB900B (hereinafter the “subject 

blender”).

6. At all times material, the subject blender was in substantially the same condition as when

it left the respective manufacturer’s and consumer seller’s possession, and there were no changes 

made to the subject blender between the time it left SHARKNINJA MANAGEMENT LLC’s 

possession and the time of the subject incident.

7. At all times material, the subject blender was in substantially the same condition as when

it left the respective manufacturer’s and consumer seller’s possession, and there were no changes 

made to the subject blender between the time it left SHARKNINJA OPERATING LLC’s possession

and the time of the subject incident.

8. On November 3, 2019, LORENZO was operating the subject blender when it suddenly

and unexpectedly disgorged its blade, which sliced through her right foot, toes, and/or tendons. 

Furthermore, the subject blender had no support to hold the blade. 

9. The defects inherent in the subject blender were not reasonably discoverable by 

LORENZO and were unknown to her at the time and place of the incident.

10. As a result, LORENZO sustained serious and permanent injuries. 

COUNT I 

STRICT LIABILITY CLAIM AGAINST SHARKNINJA MANAGEMENT LLC

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11. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

12. The subject blender was defective and unreasonably dangerous by virtue of its condition

and the failure to warn of known and foreseeable risks, insofar as it was subject to disgorgement of 

its sharp and dangerous blade suddenly and unexpectedly in the course of foreseeable use, and insofar 

as the subject blender had no support to hold the blade. 

13. The subject defect existed at the time it left the possession and control of SHARKNINJA 

MANAGEMENT LLC, and, at the time it came into the possession of LORENZO. 

14. The subject blender had not been altered and/or damaged prior to the time of the incident 

described herein and was in substantially the same condition at the time of the incident described as 

at the time it was manufactured and sold by SHARKNINJA MANAGEMENT LLC and placed in the 

stream of commerce.

15. At all relevant times, SHARKNINJA MANAGEMENT LLC was in the business of 

designing, manufacturing, inspecting, testing, distributing, selling and/or marketing blenders and did 

design, manufacture, inspect, test, distribute, sell and/or market the subject blender. 

16. The subject blender failed to perform in a manner reasonably expected in light of its 

nature and intended function when it failed and caused severe injuries.

17. The subject blender had not been misused post-sale before it failed.

18. The subject blender was within its anticipated useful life when it failed.

19. The subject blender’s failure was such that would not have occurred in the absence of a 

defect or unreasonably dangerous condition within it.

20. Specifically, the subject blender was unreasonably dangerous and/or defective in that:

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a. it was dangerous to an extent beyond that which would be contemplated by the 

ordinary consumer who purchases and/or uses it, with the ordinary knowledge

common to the community as to its characteristics; and/or

b. a reasonably prudent manufacturer would not have put it on the market assuming 

that manufacturer knew of its dangerous condition.

21. As a direct and proximate result of the defective and unreasonably dangerous conditions 

of the subject blender, it suddenly and without warning disgorged its sharp and dangerous blade,

which lacked adequate support to hold it, causing LORENZO’s incident and serious injuries. 

22. As a direct and proximate result of the defective and unreasonably dangerous condition 

of the subject blender and the resulting incident as described, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT II 

NEGLGIENCE CLAIM AGAINST SHARKNINJA MANAGEMENT LLC

23. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

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24. At all times material SHARKNINJA MANAGEMENT LLC had a duty to LORENZO

to exercise reasonable care in the design, testing and manufacture of the subject blender as described

in the incident above.

25. SHARKNINJA MANAGEMENT LLC knew, or in the existence of ordinary care, 

should have known, that the subject blender was defective and unreasonably dangerous to those 

persons likely to use the product for the purpose and in the manner for which it was intended to be 

used. For example, SHARKNINJA MANAGEMENT LLC has previously been sued in this circuit, 

district, and throughout this nation for similar malfunctions. See Wallace et al. v. Sharkninja 

Operating LLC, Case 5:18-cv-05221-BLF; see also Warner v. Sharkninja Operating LLC, Case 3:22-

cv-00310-JCS; see also Mawla, et al. v. Sharkninja Operating, LLC, Case 3:21-cv-05202-JD; see also 

Moberly v. Sharkninja Operating LLC, et al., Case 2:22-cv-14259-AMC; see also Gallo, et al., v. 

BJ’S WHOLESALE CLUB, INC., et al., Case 1:20-cv-22907-CMA.

26. Alternatively, SHARKNINJA MANAGEMENT LLC knew, or in the exercise of 

ordinary care should have known, of the means of designing, manufacturing and/or marketing the 

subject blender such that the type of incident and resulting injuries and damages as described herein 

would have been prevented.

27. Alternatively, SHARKNINJA MANAGEMENT LLC had actual or constructive 

knowledge of the means of designing a blender that would not be inadequate and dangerous, and 

notwithstanding this knowledge, SHARKNINJA MANAGEMENT LLC failed to adequately design, 

equip and/or manufacture the subject blender. 

28. Alternatively, SHARKNINJA MANAGEMENT LLC negligently failed to give 

adequate warnings or instructions, and/or failed to make appropriate post-marketing effortsto prevent 

known incidents, such as the one included herein.

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29. Alternatively, SHARKNINJA MANAGEMENT LLC failed to adequately design, 

manufacture, test, inspect, market and/or sell the subject blender, and/or failed to include a reasonable 

and safer alternative to the subject defective condition.

30. Alternatively, SHARKNINJA MANAGEMENT LLC failed to adequately monitor 

consumer injury and damage reports associated with the subject blender, and/or failed to include a

reasonable and safer alternatives to the subject defective condition.

31. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s 

negligence, the subject blender suddenly and without warning disgorged its sharp and dangerous 

blade, which lacked adequate support to hold it, causing LORENZO’s incident and serious injuries. 

32. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s 

negligence, LORENZO suffered bodily injury and resulting pain and suffering, disability, 

disfigurement, mental anguish, loss of capacity for the enjoyment of life, the expense of 

hospitalization, medical and nursing care and treatment, rehabilitative expenses, and inconvenience. 

The losses are permanent and continuing in nature and LORENZO will suffer these losses in the 

future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT III

BREACH OF EXPRESS WARRANTY AGAINST SHARKNINJA MANAGEMENT LLC

33. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

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34. SHARKNINJA MANAGEMENT LLC designed, manufactured, assembled, 

distributed, inspected, tested and/or sold the subject blender. 

35. SHARKNINJA MANAGEMENT LLC expressly warranted that the subject blender

was safe for ordinary use when used in compliance with the instructions provided, which LORENZO 

followed.

36. SHARKNINJA MANAGEMENT LLC’s affirmations regarding the safety of its 

product formed a basis of the bargain for LORENZO without which LORENZO would not have 

purchased and/or used the subject blender. 

37. The subject blender did not conform to SHARKNINJA MANAGEMENT LLC’s 

affirmations regarding safety.

38. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

express warranties, the subject blender suddenly and without warning disgorged its sharp and 

dangerous blade, which lacked adequate support to hold it, causing LORENZO’s incident and serious 

injuries. 

39. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

express warranties, LORENZO suffered bodily injury and resulting pain and suffering, disability, 

disfigurement, mental anguish, loss of capacity for the enjoyment of life, the expense of 

hospitalization, medical and nursing care and treatment, rehabilitative expenses, and inconvenience. 

The losses are permanent and continuing in nature and LORENZO will suffer these losses in the 

future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

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Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT IV

BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY AGAINST

SHARKNINJA MANAGEMENT LLC

40. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

41. SHARKNINJA MANAGEMENT LLC at all relevant times designed, manufactured,

assembled, tested, inspected, distributed, marketed and/or sold the subject blender. 

42. SHARKNINJA MANAGEMENT LLC impliedly warranted that the subject blender

was merchantable, fit for the ordinary purpose for which it was sold or used, was of fair average 

quality as to pass without objection in the trade, and conformed to SHARKNINJA MANAGEMENT 

LLC’s own affirmations regarding the subject blender’s safety features and overall safe condition.

43. SHARKNINJA MANAGEMENT LLC breached their implied warranty of 

merchantability, as the product did not conform to SHARKNINJA MANAGEMENT LLC’s 

affirmations regarding the safety features and overall safe condition of the subject blender, the subject 

blender was not fit for the ordinary purpose for which it was sold or used, and/or was not of fair 

average quality so as to pass without objection in the trade.

44. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

the implied warranty of merchantability, the subject blender suddenly and without warning disgorged 

its sharp and dangerous blade, which lacked adequate support to hold it, causing LORENZO’s

incident and serious injuries. 

45. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

the implied warranty of merchantability, LORENZO suffered bodily injury and resulting pain and 

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

expense of hospitalization, medical and nursing care and treatment, rehabilitative expenses, and

inconvenience. The losses are permanent and continuing in nature and LORENZO will suffer these 

losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT V

BREACH OF IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR

PURPOSE AGAINST SHARKNINJA MANAGEMENT LLC

46. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

47. SHARKNINJA MANAGEMENT LLC designed, manufactured, assembled, tested, 

inspected, distributed, marketed and/or sold the subject blender. 

48. In selling the subject blender to LORENZO, SHARKNINJA MANAGEMENT LLC, 

through its agents, servants, employees, and apparent agents, acting within the scope of their

employment, authority, or apparent authority, made representations and promotions concerning the 

particular purpose to which LORENZO would put the subject blender to use and knew or should have 

known of the particular purpose to which LORENZO would put the product to use. SHARKNINJA 

MANAGEMENT LLC impliedly warranted that the product would be fit for such particular purpose.

49. SHARKNINJA MANAGEMENT LLC breached its implied warranty of fitness for a 

particular purpose, as the subject blender did not conform to SHARKNINJA MANAGEMENT 

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LLC’s affirmations regarding its product being fit for such particular purpose. The subject blender’s 

malfunctioning safety features and overall unsafe condition rendered it unfit for that purpose.

50. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

the implied warranty of fitness for a particular purpose, the subject blender suddenly and without 

warning disgorged its sharp and dangerous blade, which lacked adequate support to hold it, causing 

LORENZO’s incident and serious injuries. 

51. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s breach of 

the implied warranty of fitness for a particular purpose, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT VI

FAILURE TO WARN AGAINST SHARKNINJA MANAGEMENT LLC

52. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

53. SHARKNINJA MANAGEMENT LLC designed, manufactured, assembled, tested, 

inspected, distributed, marketed and/or sold the subject blender. 

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54. On or about November 3, 2019, LORENZO used the subject blender in the manner

intended and/or foreseeably intended, when the subject blender failed and/or otherwise caused injury 

to LORENZO. 

55. The subject blender was manufactured in a defective manner, was defectively designed, 

failed to have adequate and proper warnings or instructions, was not safe to be used for the purposes 

intended, and/or was otherwise inherently and/or unreasonably dangerous.

56. SHARKNINJA MANAGEMENT LLC knew or should have known of the dangerous 

nature of the subject blender by virtue of its business, and/or knew or should have known of the need 

to provide adequate warnings concerning the use of the subject blender. For example, SHARKNINJA 

MANAGEMENT LLC has previously been sued in this circuit, district, and throughout this nation 

for similar malfunctions. See Wallace et al. v. Sharkninja Operating LLC, Case 5:18-cv-05221-BLF; 

see also Warner v. Sharkninja Operating LLC, Case 3:22-cv-00310-JCS; see also Mawla, et al. v. 

Sharkninja Operating, LLC, Case 3:21-cv-05202-JD; see also Moberly v. Sharkninja Operating LLC, 

et al., Case 2:22-cv-14259-AMC; see also Gallo, et al., v. BJ’S WHOLESALE CLUB, INC., et al., 

Case 1:20-cv-22907-CMA.

57. SHARKNINJA MANAGEMENT LLC had a duty to provide reasonable warnings of 

dangers involved in the use of the subject blender, and failed to provide the public, including

LORENZO, notice of the danger involved.

58. As a direct and proximate result of SHARKNINJA MANAGEMENT LLC’s failure to 

warn of the dangers of the subject blender, LORENZO was unable to protect herself or otherwise 

avoid injury when her incident occurred. 

59. As a direct and proximate result of the foregoing, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

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enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA MANAGEMENT LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT I 

STRICT LIABILITY CLAIM AGAINST SHARKNINJA OPERATING LLC

60. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

61. The subject blender was defective and unreasonably dangerous by virtue of its condition

and the failure to warn of known and foreseeable risks, insofar as it was subject to disgorgement of 

its sharp and dangerous blade suddenly and unexpectedly in the course of foreseeable use, and insofar 

as the subject blender had no support to hold the blade. 

62. The subject defect existed at the time it left the possession and control of SHARKNINJA 

OPERATING LLC, and, at the time it came into the possession of LORENZO. 

63. The subject blender had not been altered and/or damaged prior to the time of the incident 

described herein and was in substantially the same condition at the time of the incident described as 

at the time it was manufactured and sold by SHARKNINJA OPERATING LLC and placed in the 

stream of commerce.

64. At all relevant times, SHARKNINJA OPERATING LLC was in the business of 

designing, manufacturing, inspecting, testing, distributing, selling and/or marketing blenders and did 

design, manufacture, inspect, test, distribute, sell and/or market the subject blender. 

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65. The subject blender failed to perform in a manner reasonably expected in light of its 

nature and intended function when it failed and caused severe injuries.

66. The subject blender had not been misused post-sale before it failed.

67. The subject blender was within its anticipated useful life when it failed.

68. The subject blender’s failure was such that would not have occurred in the absence of a 

defect or unreasonably dangerous condition within it.

69. Specifically, the subject blender was unreasonably dangerous and/or defective in that:

a. it was dangerous to an extent beyond that which would be contemplated by the 

ordinary consumer who purchases and/or uses it, with the ordinary knowledge

common to the community as to its characteristics; and/or

b. a reasonably prudent manufacturer would not have put it on the market assuming 

that manufacturer knew of its dangerous condition.

70. As a direct and proximate result of the defective and unreasonably dangerous conditions 

of the subject blender, it suddenly and without warning disgorged its sharp and dangerous blade,

which lacked adequate support to hold it, causing LORENZO’s incident and serious injuries. 

71. As a direct and proximate result of the defective and unreasonably dangerous condition 

of the subject blender and the resulting incident as described, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

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Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT II 

NEGLGIENCE CLAIM AGAINST SHARKNINJA OPERATING LLC

72. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

73. At all times material SHARKNINJA OPERATING LLC had a duty to LORENZO to 

exercise reasonable care in the design, testing and manufacture of the subject blender as described in 

the incident above.

74. SHARKNINJA OPERATING LLC knew, or in the existence of ordinary care, should 

have known, that the subject blender was defective and unreasonably dangerous to those persons 

likely to use the product for the purpose and in the manner for which it was intended to be used. For 

example, SHARKNINJA OPERATING LLC has previously been sued in this circuit, district, and 

throughout this nation for similar malfunctions. See Wallace et al. v. Sharkninja Operating LLC, Case 

5:18-cv-05221-BLF; see also Warner v. Sharkninja Operating LLC, Case 3:22-cv-00310-JCS; see 

also Mawla, et al. v. Sharkninja Operating, LLC, Case 3:21-cv-05202-JD; see also Moberly v. 

Sharkninja Operating LLC, et al., Case 2:22-cv-14259-AMC; see also Gallo, et al., v. BJ’S 

WHOLESALE CLUB, INC., et al., Case 1:20-cv-22907-CMA.

75. Alternatively, SHARKNINJA OPERATING LLC knew, or in the exercise of ordinary 

care should have known, of the means of designing, manufacturing and/or marketing the subject 

blender such that the type of incident and resulting injuries and damages as described herein would 

have been prevented.

76. Alternatively, SHARKNINJA OPERATING LLC had actual or constructive knowledge 

of the means of designing a blender that would not be inadequate and dangerous, and notwithstanding 

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this knowledge, SHARKNINJA OPERATING LLC failed to adequately design, equip and/or 

manufacture the subject blender. 

77. Alternatively, SHARKNINJA OPERATING LLC negligently failed to give adequate 

warnings or instructions, and/or failed to make appropriate post-marketing efforts to prevent known 

incidents, such as the one included herein.

78. Alternatively, SHARKNINJA OPERATING LLC failed to adequately design, 

manufacture, test, inspect, market and/or sell the subject blender, and/or failed to include a reasonable 

and safer alternative to the subject defective condition.

79. Alternatively, SHARKNINJA OPERATING LLC failed to adequately monitor 

consumer injury and damage reports associated with the subject blender, and/or failed to include a

reasonable and safer alternatives to the subject defective condition.

80. As a direct and proximate result of SHARKNINJA OPERATING LLC’s negligence, the 

subject blender suddenly and without warning disgorged its sharp and dangerous blade, which lacked

adequate support to hold it, causing LORENZO’s incident and serious injuries. 

81. As a direct and proximate result of SHARKNINJA OPERATING LLC’s negligence, 

LORENZO suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental 

anguish, loss of capacity for the enjoyment of life, the expense of hospitalization, medical and nursing 

care and treatment, rehabilitative expenses, and inconvenience. The losses are permanent and 

continuing in nature and LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

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COUNT III

BREACH OF EXPRESS WARRANTY AGAINST SHARKNINJA OPERATING LLC

82. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

83. SHARKNINJA OPERATING LLC designed, manufactured, assembled, distributed,

inspected, tested and/or sold the subject blender. 

84. SHARKNINJA OPERATING LLC expressly warranted that the subject blender was 

safe for ordinary use when used in compliance with the instructions provided, which LORENZO 

followed.

85. SHARKNINJA OPERATING LLC’s affirmations regarding the safety of its product 

formed a basis of the bargain for LORENZO without which LORENZO would not have purchased 

and/or used the subject blender. 

86. The subject blender did not conform to SHARKNINJA OPERATING LLC’s 

affirmations regarding safety.

87. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of 

express warranties, the subject blender suddenly and without warning disgorged its sharp and 

dangerous blade, which lacked adequate support to hold it, causing LORENZO’s incident and serious 

injuries. 

88. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of 

express warranties, LORENZO suffered bodily injury and resulting pain and suffering, disability, 

disfigurement, mental anguish, loss of capacity for the enjoyment of life, the expense of 

hospitalization, medical and nursing care and treatment, rehabilitative expenses, and inconvenience. 

The losses are permanent and continuing in nature and LORENZO will suffer these losses in the 

future.

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WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT IV

BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY AGAINST

SHARKNINJA OPERATING LLC

89. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

90. SHARKNINJA OPERATING LLC at all relevant times designed, manufactured,

assembled, tested, inspected, distributed, marketed and/or sold the subject blender. 

91. SHARKNINJA OPERATING LLC impliedly warranted that the subject blender was

merchantable, fit for the ordinary purpose for which it was sold or used, was of fair average quality 

as to pass without objection in the trade, and conformed to SHARKNINJA OPERATING LLC’s own 

affirmations regarding the subject blender’s safety features and overall safe condition.

92. SHARKNINJA OPERATING LLC breached their implied warranty of merchantability, 

as the product did not conform to SHARKNINJA OPERATING LLC’s affirmations regarding the 

safety features and overall safe condition of the subject blender, the subject blender was not fit for the

ordinary purpose for which it was sold or used, and/or was not of fair average quality so as to pass 

without objection in the trade.

93. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of the 

implied warranty of merchantability, the subject blender suddenly and without warning disgorged its 

sharp and dangerous blade, which lacked adequate support to hold it, causing LORENZO’s incident

and serious injuries. 

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94. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of the 

implied warranty of merchantability, LORENZO suffered bodily injury and resulting pain and 

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

expense of hospitalization, medical and nursing care and treatment, rehabilitative expenses, and

inconvenience. The losses are permanent and continuing in nature and LORENZO will suffer these 

losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT V

BREACH OF IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR

PURPOSE AGAINST SHARKNINJA OPERATING LLC

95. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

96. SHARKNINJA OPERATING LLC designed, manufactured, assembled, tested, 

inspected, distributed, marketed and/or sold the subject blender. 

97. In selling the subject blender to LORENZO, SHARKNINJA OPERATING LLC, 

through its agents, servants, employees, and apparent agents, acting within the scope of their

employment, authority, or apparent authority, made representations and promotions concerning the 

particular purpose to which LORENZO would put the subject blender to use and knew or should have 

known of the particular purpose to which LORENZO would put the product to use. SHARKNINJA 

OPERATING LLC impliedly warranted that the product would be fit for such particular purpose.

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98. SHARKNINJA OPERATING LLC breached its implied warranty of fitness for a 

particular purpose, as the subject blender did not conform to SHARKNINJA OPERATING LLC’s

affirmations regarding its product being fit for such particular purpose. The subject blender’s 

malfunctioning safety features and overall unsafe condition rendered it unfit for that purpose.

99. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of the 

implied warranty of fitness for a particular purpose, the subject blender suddenly and without warning 

disgorged its sharp and dangerous blade, which lacked adequate support to hold it, causing 

LORENZO’s incident and serious injuries. 

100. As a direct and proximate result of SHARKNINJA OPERATING LLC’s breach of the 

implied warranty of fitness for a particular purpose, LORENZO suffered bodily injury and resulting 

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

life, the expense of hospitalization, medical and nursing care and treatment, rehabilitative expenses, 

and inconvenience. The losses are permanent and continuing in nature and LORENZO will suffer 

these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

COUNT VI

FAILURE TO WARN AGAINST SHARKNINJA OPERATING LLC

101. LORENZO realleges and readopts the allegations set forth in Paragraphs 1-8 as if fully 

set forth herein.

102. SHARKNINJA OPERATING LLC designed, manufactured, assembled, tested, 

inspected, distributed, marketed and/or sold the subject blender. 

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103. On or about November 3, 2019, LORENZO used the subject blender in the manner

intended and/or foreseeably intended, when the subject blender failed and/or otherwise caused injury 

to LORENZO. 

104. The subject blender was manufactured in a defective manner, was defectively designed, 

failed to have adequate and proper warnings or instructions, was not safe to be used for the purposes 

intended, and/or was otherwise inherently and/or unreasonably dangerous.

105. SHARKNINJA OPERATING LLCknew or should have known of the dangerous nature 

of the subject blender by virtue of its business, and/or knew or should have known of the need to 

provide adequate warnings concerning the use of the subject blender. For example, SHARKNINJA 

OPERATING LLC has previously been sued in this circuit, district, and throughout this nation for 

similar malfunctions. See Wallace et al. v. Sharkninja Operating LLC, Case 5:18-cv-05221-BLF; see 

also Warner v. Sharkninja Operating LLC, Case 3:22-cv-00310-JCS; see also Mawla, et al. v. 

Sharkninja Operating, LLC, Case 3:21-cv-05202-JD; see also Moberly v. Sharkninja Operating LLC, 

et al., Case 2:22-cv-14259-AMC; see also Gallo, et al., v. BJ’S WHOLESALE CLUB, INC., et al., 

Case 1:20-cv-22907-CMA.

106. SHARKNINJA OPERATING LLC had a duty to provide reasonable warnings of 

dangers involved in the use of the subject blender, and failed to provide the public, including

LORENZO, notice of the danger involved.

107. As a direct and proximate result of SHARKNINJA OPERATING LLC’s failure to warn 

of the dangers of the subject blender, LORENZO was unable to protect herself or otherwise avoid 

injury when her incident occurred. 

108. As a direct and proximate result of the foregoing, LORENZO suffered bodily injury and 

resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

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enjoyment of life, the expense of hospitalization, medical and nursing care and treatment, 

rehabilitative expenses, and inconvenience. The losses are permanent and continuing in nature and 

LORENZO will suffer these losses in the future.

WHEREFORE, Plaintiff, RACHEL LORENZO demands judgment against Defendant, 

SHARKNINJA OPERATING LLC, for compensatory damages in an amount in excess of Fifteen 

Thousand Dollars ($15,000.00), plus costs, and demand trial by jury of all issues triable as of right by 

a jury.

DEMAND FOR JURY TRIAL

Plaintiff, RACHEL LORENZO, demands trial by jury on all issues so triable. 

Dated: September 8, 2022. 

Respectfully submitted,

/s/ Matthias M. Hayashi 

Spencer M. Aronfeld, Esq.

Florida Bar No.: 905161

aronfeld@Aronfeld.com 

Abby H. Ivey, Esq.

Florida Bar No.: 1002774 

aivey@aronfeld.com

Matthias M. Hayashi

Florida Bar No.: 115973

mhayashi@aronfeld.com

ARONFELD TRIAL LAWYERS

One Alhambra Plaza, Penthouse 

Coral Gables, Florida 33134 

P: (305) 441.0440 

F: (305) 441.0198 

Attorneys for LORENZO

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