UNITED STATES DISTRICT COURT

DISTRICT OF JERSEY, CAMDEN

JOAN WEINER

4217 Pine Street

Philadelphia, Pennsylvania 19104

v.

TRUMP MARINA

Huron Avenue and Brigantine Boulevard 

Atlantic City, New Jersey 08401

TRUMP MARINA ASSOCIATES, L.P.

d/b/a Trump Marina

Huron Avenue and Brigantine Boulevard

Atlantic City, New Jersey 08401

TRUMP MARINA, INC.

d/b/a Trump Marina

Huron Avenue and Brigantine Boulevard

Atlantic City, New Jersey 08401

TRUMP MARINA ASSOCIATES, LLC

d/b/a Trump Marina

Huron Avenue and Brigantine Boulevard

Atlantic City, New Jersey 08401

TRUMP ENTERTAINMENT RESORTS, INC.

15 South Pennsylvania Avenue

Atlantic City, New Jersey 08401

TRUMP HOTELS & CASINO RESORTS, 

INC.

1000 Boardwalk

Atlantic City, New Jersey 08041

JOHN DOES 1-10

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DOCKET NO. 

COMPLAINT

JURY TRIAL DEMANDED

Plaintiff, Joan Weiner, by and through her attorneys, Sheridan & Murray, LLC, hereby 

submits the following Complaint and in support thereof, avers the following:

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I. THE PARTIES

1. Plaintiff, Joan Weiner, is an adult citizen of the State of Pennsylvania, residing 

therein at 4217 Pine Street, Philadelphia, Pennsylvania 19104.

2. Defendant, Trump Marina, is, upon information and belief, a hotel casino and 

corporation organized and existing under the laws of the State of New Jersey, duly authorized 

to conduct business in the State of New Jersey, and regularly conducting business therein with 

a principal place of business located at Huron Avenue and Brigantine Boulevard, Atlantic City, 

New Jersey 08401.

3. Defendant, Trump Marina, Inc., d/b/a Trump Marina, is, upon information and 

belief, a corporation organized and existing under the laws of the State of New Jersey, duly 

authorized to conduct business in the State of New Jersey, regularly conducting business 

therein with a principal place of business located at Huron Avenue and Brigantine Boulevard, 

Atlantic City, New Jersey 08401.

4. Defendant, Trump Marina Associates, L.P., d/b/a Trump Marina, is, upon 

information and belief, a corporation organized and existing under the laws of the State of New 

Jersey, duly authorized to conduct business in the State of New Jersey, regularly conducting 

business therein with a principal place of business located at Huron Avenue and Brigantine 

Boulevard, Atlantic City, New Jersey 08401.

5. Defendant, Trump Marina Associates, LLC, d/b/a Trump Marina, is, upon 

information and belief, a corporation organized and existing under the laws of the State of New 

Jersey, duly authorized to conduct business in the State of New Jersey, regularly conducting 

business therein with a principal place of business located at Huron Avenue and Brigantine 

Boulevard, Atlantic City, New Jersey 08401.

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6. Defendant, Trump Entertainment Resorts, Inc., (hereinafter Trump 

Entertainment) is upon information and belief, a corporation organized and existing under the 

laws of the State of New Jersey that regularly conducts business at Defendant, Trump Marina, 

with a principal place of business located at 15 South Pennsylvania Avenue, Atlantic City, New 

Jersey 08401.

7. Defendant Trump Hotels & Casino Resorts, Inc., (hereinafter Trump Hotels) is 

upon information and belief, a corporation organized and existing under the laws of the State 

of New Jersey that regularly conducts business at Defendant, Trump Marina, with a principal 

place of business located at 1000 Boardwalk, Atlantic City, New Jersey 08401.

8. Defendants, John Does 1-10, were/are, upon information and belief, 

corporations, agents, companies, entities, individuals, contractors, subcontractors, and/or 

businesses responsible for the operation, ownership, management, and control of the hotel 

casino, Defendant Trump Marina, located at Huron Avenue and Brigantine Boulevard, Atlantic 

City, New Jersey 08401.

9. At all times material hereto, the Defendant(s) owned, operated, possessed, 

maintained, and/or controlled the Defendant Trump Marina Hotel Casino located at Huron 

Avenue and Brigantine Boulevard, Atlantic City, New Jersey 08401.

10. At all times material hereto, the Defendant(s) acted and/or failed to act by and 

through their actual and/or apparent agents, servants, workmen, employees, representatives, 

independent contractors, and/or ostensible agents, who was/were acting within the course and 

scope of their actual and/or apparent employment, agency, representation, and/or ostensible 

agency, and in furtherance of Defendants’ interests.

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II. JURISDICTION AND VENUE

11. This Court has jurisdiction based upon the diversity of citizenship of the parties 

and the requisite amount in controversy is in excess of Seventy-Five Thousand ($75,000.00) 

Dollars, exclusive of interest, costs, pursuant to 28 U.S.C. § 1332.

12. Venue is appropriate in this District because the Defendants are subject to 

personal jurisdiction in this judicial district and the underlying negligence and carelessness of 

the Defendants in causing this accident, described more fully below, occurred at Defendant 

Trump Marina at Huron Avenue and Brigantine Boulevard, Atlantic City, New Jersey, which is 

within this judicial district.

III. FACTUAL AVERMENTS

13. At all times material hereto, Defendants, Trump Marina, Trump Marina 

Associates, L.P., Trump Marina, Inc. Trump Marina Associates, LLC, Trump Entertainment, 

Trump Hotels and Defendants John Does 1-10, upon information and belief, owned, operated, 

possessed, maintained, and/or controlled the Defendant Trump Marina.

14. At all times material hereto, Defendants, Trump Marina, Trump Marina 

Associates, L.P., Trump Marina, Inc., Trump Marina Associates, LLC, Trump Entertainment, 

Trump Hotels and Defendants John Does 1-10, upon information and belief, owned, operated, 

possessed, maintained, and/or controlled Room 2302 of Defendant Trump Marina (hereinafter 

referred to as “the Premises”).

15. At all times material hereto, Defendant Trump Marina, upon information and 

belief, had a duty to keep, inspect, repair, maintain, and/or control the Premises in a 

reasonable and safe condition and a further duty to ensure that all persons utilizing the 

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premises were not injured as a result of the negligence, carelessness and/or recklessness of 

the Defendants.

16. At all times material hereto, Defendant Trump Marina Inc., upon information and 

belief, had a duty to keep, inspect, repair, maintain, and/or control the Premises in a 

reasonable and safe condition and a further duty to ensure that all persons utilizing the 

premises were not injured as a result of the negligence, carelessness and/or recklessness of 

the Defendants.

17. At all times material hereto, Defendant Trump Marina Associates, L.P., upon 

information and belief, had a duty to keep, inspect, repair, maintain, and/or control the 

Premises in a reasonable and safe condition and a further duty to ensure that all persons 

utilizing the premises were not injured as a result of the negligence, carelessness and/or 

recklessness of the Defendants.

18. At all times material hereto, Defendant Trump Marina Associates, LLC, upon 

information and belief, had a duty to keep, inspect, repair, maintain, and/or control the 

Premises in a reasonable and safe condition and a further duty to ensure that all persons 

utilizing the premises were not injured as a result of the negligence, carelessness and/or 

recklessness of the Defendants.

19. At all times material hereto, Defendant Trump Entertainment upon information 

and belief, had a duty to keep, inspect, repair, maintain, and/or control the Premises in a 

reasonable and safe condition and a further duty to ensure that all persons utilizing the 

premises were not injured as a result of the negligence, carelessness and/or recklessness of 

the Defendants.

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20. At all times material hereto, Defendant Trump Hotels upon information and belief, 

had a duty to keep, inspect, repair, maintain, and/or control the Premises in a reasonable and 

safe condition and a further duty to ensure that all persons utilizing the premises were not 

injured as a result of the negligence, carelessness and/or recklessness of the Defendants.

21. At all times material hereto, Defendants John Does 1-10 upon information and 

belief, had a duty to keep, inspect, repair, maintain, and/or control the Premises in a 

reasonable and safe condition and a further duty to ensure that all persons utilizing the 

premises were not injured as a result of the negligence, carelessness and/or recklessness of 

the Defendants.

22. At all times material hereto, the Defendant(s) had a duty to maintain the 

Premises in a reasonable and safe condition.

23. At all times relevant and material hereto, Defendant(s) had a duty to inspect the 

Premises for hazardous and dangerous conditions.

24. At all times relevant and material hereto, Defendant(s) had a duty to repair, 

remove, and/or eliminate hazards and dangerous conditions in the Premises.

25. At all times relevant and material hereto, Defendant(s) had a duty to ensure that 

the premises was in a reasonably safe condition, and free of any dangerous conditions.

26. At all times relevant and material hereto, Defendant(s) had a duty to warn, or 

otherwise protect, persons from any known or knowable dangerous conditions and/or hazards 

on the Premises.

27. At all times relevant and material hereto, Plaintiff, Joan Weiner, was patron and 

business invitee of Defendant(s).

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28. At all times relevant and material hereto, Plaintiff, Joan Weiner, was lawfully 

upon the Premises.

29. On December 10, 2008, Plaintiff, Joan Weiner, a patron at Trump Marina, was 

severely injured when she fell after stepping onto the bathroom floor of the Premises. She was 

caused to fall due to the hazardous and dangerous condition of the bathroom’s floor surface 

due to the negligence and carelessness of the Defendants.

30. At all times relevant and material hereto, Plaintiff was exercising due care for her 

own safety.

31. This incident was directly, proximately, and solely caused by the negligence and 

carelessness of the Defendant(s) as set forth more fully hereinafter.

32. At all times relevant and material hereto, Defendant(s) negligently, carelessly, 

and recklessly failed to have non-slip and/or slip resistant floors in the bathroom of the 

Premises at the time of this incident.

33. At all times relevant and material hereto, the Defendant(s) negligently, carelessly, 

and recklessly failed to have anti-slip and/or slip resistant protection on the bathroom floor of 

the Premises at the time of this incident.

34. At all times relevant and material hereto, Defendant(s) negligently, carelessly, 

and recklessly failed to have an appropriate floor mat or other similar covering on the bathroom 

floor of the Premises at the time of this incident.

35. At all times relevant and material hereto, it was, or should have been, reasonably 

foreseeable to the Defendant(s) that persons, like the Plaintiff, would be stepping onto the 

bathroom floor on the Premises and be exposed to this hazardous and dangerous condition.

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36. At all times relevant and material hereto, it was, or should have been, reasonably 

foreseeable to the Defendant(s) that persons exposed to this hazard and danger could be 

injured in a manner similar to the Plaintiff.

37. At all times material and relevant hereto, the Defendant(s) failed to provide 

Plaintiff was a safe means of walking on the bathroom floor of the Premises.

38. At all times relevant and material hereto, the Defendant(s) failed to conduct 

reasonable inspections of the bathroom of the Premises to identify dangerous conditions 

and/or hazards.

39. At all times material hereto, the Defendant(s) failed to take reasonable steps to 

ensure that the bathroom of the Premises was in a safe condition and free of dangerous 

conditions and/or hazards so as to prevent injuries to persons upon the property.

40. The above referenced incident was directly and proximately caused by the 

negligence, carelessness and/or recklessness of the Defendants, as set forth more fully in this 

Complaint.

41. As a direct and proximate result of the negligence, carelessness, and/or 

recklessness of the Defendant(s), Plaintiff, Joan Weiner, has sustained serious and permanent 

injuries and loss of loss of body function, including but not limited to the following: torn and 

damaged ligaments and structures in the right wrist requiring surgical repair, right wrist 

scarring, loss of function in the right wrist and hand, anticipated future surgery on the right 

wrist, multiple contusions and bruises to her body, shock to her nerves and nervous system, 

mental anguish, embarrassment and distress.

42. The personal injuries sustained by the Plaintiff constitute a serious, substantial 

and permanent impairment and loss of bodily functions.

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43. As a direct and proximate result of the negligence, carelessness and/or 

recklessness of the Defendant(s), the Plaintiff has suffered and will continue to suffer great 

physical pain, discomfort, trauma, humiliation, anxiety, and/or mental anguish and will continue 

to endure the same for an indefinite period of time in the future, to her great physical, 

emotional, and financial detriment, and requiring continued medical care, monitoring, and 

treatment.

44. As a direct and proximate result of the negligence, carelessness, and/or 

recklessness of the Defendant(s) the Plaintiff is subject to an increase risk that she will develop 

future complications and injuries that will require future medical monitoring and medical 

treatment in the future.

45. As a direct and proximate result of the negligence, carelessness, and/or 

recklessness of the Defendant(s), Plaintiff has been compelled, in order to attempt to affect a 

cure of the aforementioned injuries, to expend large and various sums of money for medicine 

and medical care and may be required to expend large sums of money for the same purposes 

in the future.

46. As a direct and proximate result of the negligence, carelessness, and/or 

recklessness of the Defendant(s), the Plaintiff has been prevented and will be prevented from 

engaging in her usual activities, avocations, occupations, and lifestyles, all to her great 

personal and financial loss and detriment.

47. As a direct and proximate result of the negligence, carelessness, and/or 

recklessness of the Defendant(s), the Plaintiff was unable to work for a period of time and 

suffered a loss of earnings and impairment of her earning capacity.

48. All Defendants are jointly and severally liable to the Plaintiff.

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COUNT I – NEGLIGENCE

JOAN WEINER v. TRUMP MARINA

49. Plaintiff hereby incorporates by reference the averments set forth in paragraphs 1 

through 48 inclusive as set forth at length herein.

50. At all times material hereto, Defendant Trump Marina directly, and by and 

through its employees, agents, workmen, and contractors, owed a duty to Plaintiff and persons 

in Plaintiff’s position to exercise due and ordinary care in the operation of its activities, 

including but not limited to maintenance, inspection, safety, and/or control of the Premises.

51. At all times material hereto, Defendant Trump Marina directly, by and through its 

employees, agents, workmen, and contractors, had a duty to make, design, inspect, repair, 

control, and/or maintain the Premises in a reasonable and safe manner.

52. Defendant Trump Marina directly, and by and through its employees, agents, 

workmen, and contractors, negligently, carelessly, and/or recklessly breached all duties owed 

to the Plaintiff by permitting the dangerous condition to exist and remain in the bathroom of the 

Premises thereby proximately causing Plaintiff’s serious and permanent injuries.

53. Plaintiff was seriously and permanently injured as a direct and proximate result of 

the negligence, carelessness, and/or reckless acts and/or omissions of Defendant Trump 

Marina directly and/or by and through its agents, employees, ostensible agents, servants, 

workmen, contractors, subcontractors, and/or representatives, which consisted of the 

following:

a. Failing to properly and adequately inspect the bathroom of the Premises 

to protect against dangerous conditions on the bathroom floor;

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b. Failure to correct or remedy a dangerous condition which it knew or 

should have known to be dangerous;

c. Failing to protect individuals lawfully in the bathroom of the Premises, 

including the Plaintiff from the dangerous condition on the bathroom floor 

of the Premises;

d. Failing to warn individuals, including the Plaintiff, of the dangerous 

condition presented by the condition of the bathroom floor;

e. Failing to post warnings, or other symbols in the bathroom of the 

Premises, notifying people of the dangerous condition of the bathroom 

floor;

f. Preventing or allowing a dangerous condition to remain in/on the 

bathroom floor of the Premises;

g. Failing to ensure that the bathroom floor of the Premises was slip 

resistant;

h. Failing to have adequate non-slip protection on the bathroom floor of the 

Premises;

i. Failing to have any bathroom mats or other similar coverings to prevent 

dangerous and slippery conditions on the bathroom floor of the Premises;

j. Failing to properly and adequately construct and/or maintain the floor of 

the bathroom of the Premises in a safe condition;

k. Failing to properly train and instruct the Defendant’s personnel, 

employees, representatives, contractors, subcontractors, and/or agents 

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with regard to the proper inspection, maintenance, and/or safety of the 

bathroom floor of the Premises;

l. Failing to ensure that the bathroom floor of the Premises was safely and 

adequately inspected and/or maintained;

m. Failing to obtain an approved plan or design for the inspection, repair, 

and/or maintenance of the bathroom floor of the Premises;

n. Failing to perform an inspection, repairs, and maintenance of the 

bathroom floor of the Premises in accordance with approved plans or 

designs, if any such plans or designs existed;

o. Failing to maintain the bathroom floor in a condition so that it was safe for 

its foreseeable use;

p. Failure to take reasonable steps to ensure that individuals lawfully in the 

bathroom of the Premises including Plaintiff, would remain free from 

unnecessary and reasonable harm;

q. Failing to regularly inspect and maintain the bathroom floor of the 

Premises to ensure that it was maintained and/or remained in a safe 

condition in accordance with the Defendants and/or other appropriate 

policies and procedures;

r. Failing to repair and/or correct the dangerous condition on the bathroom 

floor of the Premises when Defendant knew or should have known that 

such dangerous condition existed;

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s. Failing to adopt appropriate policies and/or procedures relating to the 

repair, inspection, maintenance, and/or safety of the bathroom floor of the 

Premises;

t. Failure to properly enforce its policies and/or procedures, if they existed,

relating to the inspection, control, and maintenance of the bathroom floor 

of the Premises;

u. Failing to correct, eliminate, remedy, and/or remove the dangerous 

condition and hazard from the bathroom floor of the Premises;

v. Failure to warn persons, including Plaintiff, of the dangerous condition of 

the bathroom floor of the Premises;

w. Failure to adopt proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, maintenance, and/or safety of the 

bathroom floor of the Premises, and

x. Failure to enforce proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, inspection, maintenance, and/or 

safety of the bathroom floor of the Premises.

54. As a direct and proximate result of the negligent, careless, and/or reckless acts or 

omissions of Defendants, Plaintiff has been severely and permanently injured, as set forth more 

fully in the paragraphs above.

WHEREFORE, Plaintiff, Joan Weiner, demands judgment against Defendants, Trump 

Marina, Trump Marina Associates, L.P., Trump Marina, Inc., Trump Marina Associates, LLC, 

Trump Entertainment, Trump Hotels and John Does 1-10, jointly and severally, for 

compensatory damages, which will reasonably compensate her for her injuries and losses,

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punitive damages, prejudgment and post judgment interests, costs of suit, and any other relief 

deemed equitable and just by this Honorable Court.

COUNT II – NEGLIGENCE

JOAN WEINER v. TRUMP MARINA ASSOCIATES, L.P.

55. Plaintiff hereby incorporates by reference the averments set forth in paragraphs 1 

through 52 inclusive as set forth at length herein.

56. At all times material hereto, Defendant Trump Marina Associates, L.P. directly, 

by and through its employees, agents, workmen, and contractors, owed a duty to Plaintiff and 

persons in Plaintiff’s position to exercise due and ordinary care in the operation of its activities, 

including but not limited to maintenance, inspection, safety, and/or control of the Premises.

57. At all times material hereto, Defendant Trump Marina Associates, L.P. directly, 

by and through its employees, agents, workmen, and contractors, had a duty to make, design, 

inspect, repair, control, and/or maintain the Premises in a reasonable and safe manner.

58. Defendant Trump Marina Associates, L.P. directly, and by and through its 

employees, agents, workmen, and contractors, negligently, carelessly, and/or recklessly 

breached all duties owed to the Plaintiff by permitting the dangerous condition to exist and 

remain in the bathroom of the Premises thereby approximately causing Plaintiff’s serious and 

permanent injuries.

59. Plaintiff was seriously and permanently injured as a direct and proximate result of 

the negligence, carelessness, and/or reckless acts and/or omissions of Defendant Trump 

Marina Associates, L.P. directly and/or by and through its agents, employees, ostensible 

agents, servants, workmen, contractors, subcontractors, and/or representatives, which 

consisted of the following:

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a. Failing to properly and adequately inspect the bathroom of the Premises 

to protect against dangerous conditions on the bathroom floor;

b. Failure to correct or remedy a dangerous condition which it knew or 

should have known to be dangerous;

c. Failing to protect individuals lawfully in the bathroom of the Premises, 

including the Plaintiff from the dangerous condition on the bathroom floor 

of the Premises;

d. Failing to warn individuals, including the Plaintiff, of the dangerous 

condition presented by the condition of the bathroom floor;

e. Failing to post warnings, or other symbols in the bathroom of the 

Premises, notifying people of the dangerous condition of the bathroom 

floor;

f. Preventing or allowing a dangerous condition to remain in/on the 

bathroom floor of the Premises;

g. Failing to ensure that the bathroom floor of the Premises was slip 

resistant;

h. Failing to have adequate non-slip protection on the bathroom floor of the 

Premises;

i. Failing to have any bathroom mats or other similar coverings to prevent 

dangerous and slippery conditions on the bathroom floor of the Premises;

j. Failing to properly and adequately construct and/or maintain the floor of 

the bathroom of the Premises in a safe condition;

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k. Failing to properly train and instruct the Defendant’s personnel, 

employees, representatives, contractors, subcontractors, and/or agents 

with regard to the proper inspection, maintenance, and/or safety of the 

bathroom floor of the Premises;

l. Failing to ensure that the bathroom floor of the Premises was safely and 

adequately inspected and/or maintained;

m. Failing to obtain an approved plan or design for the inspection, repair, 

and/or maintenance of the bathroom floor of the Premises;

n. Failing to perform an inspection, repairs, and maintenance of the 

bathroom floor of the Premises in accordance with approved plans or 

designs, if any such plans or designs existed;

o. Failing to maintain the bathroom floor in a condition so that it was safe for 

its foreseeable use;

p. Failure to take reasonable steps to ensure that individuals lawfully in the 

bathroom of the Premises including Plaintiff, would remain free from 

unnecessary and reasonable harm;

q. Failing to regularly inspect and maintain the bathroom floor of the 

Premises to ensure that it was maintained and/or remained in a safe 

condition in accordance with the Defendants and/or other appropriate 

policies and procedures;

r. Failing to repair and/or correct the dangerous condition on the bathroom 

floor of the Premises when Defendant knew or should have known that 

such dangerous condition existed;

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s. Failing to adopt appropriate policies and/or procedures relating to the 

repair, inspection, maintenance, and/or safety of the bathroom floor of the 

Premises;

t. Failure to properly enforce its policies and/or procedures, if they existed,

relating to the inspection, control, and maintenance of the bathroom floor 

of the Premises;

u. Failing to correct, eliminate, remedy, and/or remove the dangerous 

condition and hazard from the bathroom floor of the Premises;

v. Failure to warn persons, including Plaintiff, of the dangerous condition of 

the bathroom floor of the Premises;

w. Failure to adopt proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, maintenance, and/or safety of the 

bathroom floor of the Premises, and

x. Failure to enforce proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, inspection, maintenance, and/or 

safety of the bathroom floor of the Premises.

60. As a direct and proximate result of the negligent, careless, and/or reckless acts or 

omissions of Defendants, Plaintiff has been severely and permanently injured, as set forth more 

fully in the paragraphs above.

WHEREFORE, Plaintiff, Joan Weiner, demands judgment against Defendants, Trump 

Marina, Trump Marina Associates, L.P., Trump Marina, Inc., Trump Marina Associates, LLC, 

Trump Entertainment, Trump Hotels and John Does 1-10,jointly and severally, for 

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compensatory damages, which will reasonably compensate her for her injuries and losses, 

punitive damages, prejudgment and post judgment interests, costs of suit, and any other relief 

deemed equitable and just by this Honorable Court.

COUNT III – NEGLIGENCE

JOAN WEINER v. TRUMP MARINA, INC.

61. Plaintiff hereby incorporates by reference the averments set forth in paragraphs 1 

through 58 inclusive as set forth at length herein.

62. At all times material hereto, Defendant Trump Marina, Inc. directly, by and 

through its employees, agents, workmen, and contractors, owed a duty to Plaintiff and persons 

in Plaintiff’s position to exercise due and ordinary care in the operation of its activities, 

including but not limited to maintenance, inspection, safety, and/or control of the Premises.

63. At all times material hereto, Defendant Trump Marina, Inc. directly, by and 

through its employees, agents, workmen, and contractors, had a duty to make, design, inspect, 

repair, control, and/or maintain the Premises in a reasonable and safe manner.

64. Defendant Trump Marina, Inc. directly, and by and through its employees, 

agents, workmen, and contractors, negligently, carelessly, and/or recklessly breached all 

duties owed to the Plaintiff by permitting the dangerous condition to exist and remain in the 

bathroom of the Premises thereby approximately causing Plaintiff’s serious and permanent 

injuries.

65. Plaintiff was seriously and permanently injured as a direct and proximate result of 

the negligence, carelessness, and/or reckless acts and/or omissions of Defendant Trump 

Marina, Inc. directly and/or by and through its agents, employees, ostensible agents, servants, 

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workmen, contractors, subcontractors, and/or representatives, which consisted of the 

following:

a. Failing to properly and adequately inspect the bathroom of the Premises 

to protect against dangerous conditions on the bathroom floor;

b. Failure to correct or remedy a dangerous condition which it knew or 

should have known to be dangerous;

c. Failing to protect individuals lawfully in the bathroom of the Premises, 

including the Plaintiff from the dangerous condition on the bathroom floor 

of the Premises;

d. Failing to warn individuals, including the Plaintiff, of the dangerous 

condition presented by the condition of the bathroom floor;

e. Failing to post warnings, or other symbols in the bathroom of the 

Premises, notifying people of the dangerous condition of the bathroom 

floor;

f. Preventing or allowing a dangerous condition to remain in/on the 

bathroom floor of the Premises;

g. Failing to ensure that the bathroom floor of the Premises was slip 

resistant;

h. Failing to have adequate non-slip protection on the bathroom floor of the 

Premises;

i. Failing to have any bathroom mats or other similar coverings to prevent 

dangerous and slippery conditions on the bathroom floor of the Premises;

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j. Failing to properly and adequately construct and/or maintain the floor of 

the bathroom of the Premises in a safe condition;

k. Failing to properly train and instruct the Defendant’s personnel, 

employees, representatives, contractors, subcontractors, and/or agents 

with regard to the proper inspection, maintenance, and/or safety of the 

bathroom floor of the Premises;

l. Failing to ensure that the bathroom floor of the Premises was safely and 

adequately inspected and/or maintained;

m. Failing to obtain an approved plan or design for the inspection, repair, 

and/or maintenance of the bathroom floor of the Premises;

n. Failing to perform an inspection, repairs, and maintenance of the 

bathroom floor of the Premises in accordance with approved plans or 

designs, if any such plans or designs existed;

o. Failing to maintain the bathroom floor in a condition so that it was safe for 

its foreseeable use;

p. Failure to take reasonable steps to ensure that individuals lawfully in the 

bathroom of the Premises including Plaintiff, would remain free from 

unnecessary and reasonable harm;

q. Failing to regularly inspect and maintain the bathroom floor of the 

Premises to ensure that it was maintained and/or remained in a safe 

condition in accordance with the Defendants and/or other appropriate 

policies and procedures;

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r. Failing to repair and/or correct the dangerous condition on the bathroom 

floor of the Premises when Defendant knew or should have known that 

such dangerous condition existed;

s. Failing to adopt appropriate policies and/or procedures relating to the 

repair, inspection, maintenance, and/or safety of the bathroom floor of the 

Premises;

t. Failure to properly enforce its policies and/or procedures, if they existed,

relating to the inspection, control, and maintenance of the bathroom floor 

of the Premises;

u. Failing to correct, eliminate, remedy, and/or remove the dangerous 

condition and hazard from the bathroom floor of the Premises;

v. Failure to warn persons, including Plaintiff, of the dangerous condition of 

the bathroom floor of the Premises;

w. Failure to adopt proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, maintenance, and/or safety of the 

bathroom floor of the Premises, and

x. Failure to enforce proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, inspection, maintenance, and/or 

safety of the bathroom floor of the Premises.

66. As a direct and proximate result of the negligent, careless, and/or reckless acts or 

omissions of Defendants, Plaintiff has been severely and permanently injured, as set forth more 

fully in the paragraphs above.

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22

WHEREFORE, Plaintiff, Joan Weiner, demands judgment against Defendants, Trump 

Marina, Trump Marina Associates, L.P., Trump Marina, Inc., Trump Marina Associates, LLC, 

Trump Entertainment, Trump Hotels and John Does 1-10, jointly and severally, for 

compensatory damages, which will reasonably compensate her for her injuries and losses, 

punitive damages, prejudgment and post judgment interests, costs of suit, and any other relief 

deemed equitable and just by this Honorable Court.

COUNT IV – NEGLIGENCE

JOAN WEINER v. TRUMP MARINA ASSOCIATES, LLC

67. Plaintiff hereby incorporates by reference the averments set forth in paragraphs 1 

through 64 inclusive as set forth at length herein.

68. At all times material hereto, Defendant Trump Marina Associates, LLC directly, 

by and through its employees, agents, workmen, and contractors, owed a duty to Plaintiff and 

persons in Plaintiff’s position to exercise due and ordinary care in the operation of its activities, 

including but not limited to maintenance, inspection, safety, and/or control of the Premises.

69. At all times material hereto, Defendant Trump Marina Associates, LLC directly, 

by and through its employees, agents, workmen, and contractors, had a duty to make, design, 

inspect, repair, control, and/or maintain the Premises in a reasonable and safe manner.

70. Defendant Trump Marina Associates, LLC directly, and by and through its 

employees, agents, workmen, and contractors, negligently, carelessly, and/or recklessly 

breached all duties owed to the Plaintiff by permitting the dangerous condition to exist and 

remain in the bathroom of the Premises thereby approximately causing Plaintiff’s serious and 

permanent injuries.

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23

71. Plaintiff was seriously and permanently injured as a direct and proximate result of 

the negligence, carelessness, and/or reckless acts and/or omissions of Defendant Trump 

Marina Associates, LLC directly and/or by and through its agents, employees, ostensible 

agents, servants, workmen, contractors, subcontractors, and/or representatives, which 

consisted of the following:

a. Failing to properly and adequately inspect the bathroom of the Premises 

to protect against dangerous conditions on the bathroom floor;

b. Failure to correct or remedy a dangerous condition which it knew or 

should have known to be dangerous;

c. Failing to protect individuals lawfully in the bathroom of the Premises, 

including the Plaintiff from the dangerous condition on the bathroom floor 

of the Premises;

d. Failing to warn individuals, including the Plaintiff, of the dangerous 

condition presented by the condition of the bathroom floor;

e. Failing to post warnings, or other symbols in the bathroom of the 

Premises, notifying people of the dangerous condition of the bathroom 

floor;

f. Preventing or allowing a dangerous condition to remain in/on the 

bathroom floor of the Premises;

g. Failing to ensure that the bathroom floor of the Premises was slip 

resistant;

h. Failing to have adequate non-slip protection on the bathroom floor of the 

Premises;

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24

i. Failing to have any bathroom mats or other similar coverings to prevent 

dangerous and slippery conditions on the bathroom floor of the Premises;

j. Failing to properly and adequately construct and/or maintain the floor of 

the bathroom of the Premises in a safe condition;

k. Failing to properly train and instruct the Defendant’s personnel, 

employees, representatives, contractors, subcontractors, and/or agents 

with regard to the proper inspection, maintenance, and/or safety of the 

bathroom floor of the Premises;

l. Failing to ensure that the bathroom floor of the Premises was safely and 

adequately inspected and/or maintained;

m. Failing to obtain an approved plan or design for the inspection, repair, 

and/or maintenance of the bathroom floor of the Premises;

n. Failing to perform an inspection, repairs, and maintenance of the 

bathroom floor of the Premises in accordance with approved plans or 

designs, if any such plans or designs existed;

o. Failing to maintain the bathroom floor in a condition so that it was safe for 

its foreseeable use;

p. Failure to take reasonable steps to ensure that individuals lawfully in the 

bathroom of the Premises including Plaintiff, would remain free from 

unnecessary and reasonable harm;

q. Failing to regularly inspect and maintain the bathroom floor of the 

Premises to ensure that it was maintained and/or remained in a safe 

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25

condition in accordance with the Defendants and/or other appropriate 

policies and procedures;

r. Failing to repair and/or correct the dangerous condition on the bathroom 

floor of the Premises when Defendant knew or should have known that 

such dangerous condition existed;

s. Failing to adopt appropriate policies and/or procedures relating to the 

repair, inspection, maintenance, and/or safety of the bathroom floor of the 

Premises;

t. Failure to properly enforce its policies and/or procedures, if they existed,

relating to the inspection, control, and maintenance of the bathroom floor 

of the Premises;

u. Failing to correct, eliminate, remedy, and/or remove the dangerous 

condition and hazard from the bathroom floor of the Premises;

v. Failure to warn persons, including Plaintiff, of the dangerous condition of 

the bathroom floor of the Premises;

w. Failure to adopt proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, maintenance, and/or safety of the 

bathroom floor of the Premises, and

x. Failure to enforce proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, inspection, maintenance, and/or 

safety of the bathroom floor of the Premises.

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26

72. As a direct and proximate result of the negligent, careless, and/or reckless acts or 

omissions of Defendants, Plaintiff has been severely and permanently injured, as set forth more 

fully in the paragraphs above.

WHEREFORE, Plaintiff, Joan Weiner, demands judgment against Defendants, Trump 

Marina, Trump Marina Associates, L.P., Trump Marina, Inc., Trump Marina Associates, LLC, 

Trump Entertainment, Trump Hotels and John Does 1-10, jointly and severally, for 

compensatory damages, which will reasonably compensate her for her injuries and losses, 

punitive damages, prejudgment and post judgment interests, costs of suit, and any other relief 

deemed equitable and just by this Honorable Court.

COUNT V – NEGLIGENCE

JOAN WEINER v. TRUMP ENTERTAINMENT RESORTS, INC.

73. Plaintiff hereby incorporates by reference the averments set forth in paragraphs 1 

through 70 inclusive as set forth at length herein.

74. At all times material hereto, Defendant Trump Entertainment Resorts, Inc. 

directly, by and through its employees, agents, workmen, and contractors, owed a duty to 

Plaintiff and persons in Plaintiff’s position to exercise due and ordinary care in the operation of 

its activities, including but not limited to maintenance, inspection, safety, and/or control of the 

Premises.

75. At all times material hereto, Defendant Trump Entertainment Resorts, Inc. 

directly, by and through its employees, agents, workmen, and contractors, had a duty to make, 

design, inspect, repair, control, and/or maintain the Premises in a reasonable and safe 

manner.

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27

76. Defendant Trump Entertainment Resorts, Inc. directly, and by and through its 

employees, agents, workmen, and contractors, negligently, carelessly, and/or recklessly 

breached all duties owed to the Plaintiff by permitting the dangerous condition to exist and 

remain in the bathroom of the Premises thereby approximately causing Plaintiff’s serious and 

permanent injuries.

77. Plaintiff was seriously and permanently injured as a direct and proximate result of 

the negligence, carelessness, and/or reckless acts and/or omissions of Defendant Trump 

Entertainment Resorts, Inc. directly and/or by and through its agents, employees, ostensible 

agents, servants, workmen, contractors, subcontractors, and/or representatives, which 

consisted of the following:

a. Failing to properly and adequately inspect the bathroom of the Premises 

to protect against dangerous conditions on the bathroom floor;

b. Failure to correct or remedy a dangerous condition which it knew or 

should have known to be dangerous;

c. Failing to protect individuals lawfully in the bathroom of the Premises, 

including the Plaintiff from the dangerous condition on the bathroom floor 

of the Premises;

d. Failing to warn individuals, including the Plaintiff, of the dangerous 

condition presented by the condition of the bathroom floor;

e. Failing to post warnings, or other symbols in the bathroom of the 

Premises, notifying people of the dangerous condition of the bathroom 

floor;

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28

f. Preventing or allowing a dangerous condition to remain in/on the 

bathroom floor of the Premises;

g. Failing to ensure that the bathroom floor of the Premises was slip 

resistant;

h. Failing to have adequate non-slip protection on the bathroom floor of the 

Premises;

i. Failing to have any bathroom mats or other similar coverings to prevent 

dangerous and slippery conditions on the bathroom floor of the Premises;

j. Failing to properly and adequately construct and/or maintain the floor of 

the bathroom of the Premises in a safe condition;

k. Failing to properly train and instruct the Defendant’s personnel, 

employees, representatives, contractors, subcontractors, and/or agents 

with regard to the proper inspection, maintenance, and/or safety of the 

bathroom floor of the Premises;

l. Failing to ensure that the bathroom floor of the Premises was safely and 

adequately inspected and/or maintained;

m. Failing to obtain an approved plan or design for the inspection, repair, 

and/or maintenance of the bathroom floor of the Premises;

n. Failing to perform an inspection, repairs, and maintenance of the 

bathroom floor of the Premises in accordance with approved plans or 

designs, if any such plans or designs existed;

o. Failing to maintain the bathroom floor in a condition so that it was safe for 

its foreseeable use;

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29

p. Failure to take reasonable steps to ensure that individuals lawfully in the 

bathroom of the Premises including Plaintiff, would remain free from 

unnecessary and reasonable harm;

q. Failing to regularly inspect and maintain the bathroom floor of the 

Premises to ensure that it was maintained and/or remained in a safe 

condition in accordance with the Defendants and/or other appropriate 

policies and procedures;

r. Failing to repair and/or correct the dangerous condition on the bathroom 

floor of the Premises when Defendant knew or should have known that 

such dangerous condition existed;

s. Failing to adopt appropriate policies and/or procedures relating to the 

repair, inspection, maintenance, and/or safety of the bathroom floor of the 

Premises;

t. Failure to properly enforce its policies and/or procedures, if they existed,

relating to the inspection, control, and maintenance of the bathroom floor 

of the Premises;

u. Failing to correct, eliminate, remedy, and/or remove the dangerous 

condition and hazard from the bathroom floor of the Premises;

v. Failure to warn persons, including Plaintiff, of the dangerous condition of 

the bathroom floor of the Premises;

w. Failure to adopt proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, maintenance, and/or safety of the 

bathroom floor of the Premises, and

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30

x. Failure to enforce proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, inspection, maintenance, and/or 

safety of the bathroom floor of the Premises.

78. As a direct and proximate result of the negligent, careless, and/or reckless acts or 

omissions of Defendants, Plaintiff has been severely and permanently injured, as set forth more 

fully in the paragraphs above.

WHEREFORE, Plaintiff, Joan Weiner, demands judgment against Defendants, Trump 

Marina, Trump Marina Associates, L.P., Trump Marina, Inc., Trump Marina Associates, LLC, 

Trump Entertainment, Trump Hotels and John Does 1-10, jointly and severally, for 

compensatory damages, which will reasonably compensate her for her injuries and losses, 

punitive damages, prejudgment and post judgment interests, costs of suit, and any other relief 

deemed equitable and just by this Honorable Court.

COUNT VI – NEGLIGENCE

JOAN WEINER v. TRUMP HOTELS AND CASINO RESORTS, INC.

79. Plaintiff hereby incorporates by reference the averments set forth in paragraphs 1 

through 76 inclusive as set forth at length herein.

80. At all times material hereto, Defendant Trump Hotels directly, by and through its 

employees, agents, workmen, and contractors, owed a duty to Plaintiff and persons in 

Plaintiff’s position to exercise due and ordinary care in the operation of its activities, including 

but not limited to maintenance, inspection, safety, and/or control of the Premises.

81. At all times material hereto, Defendant Trump Hotels directly, by and through its 

employees, agents, workmen, and contractors, had a duty to make, design, inspect, repair, 

control, and/or maintain the Premises in a reasonable and safe manner.

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31

82. Defendant Trump Hotels directly, and by and through its employees, agents, 

workmen, and contractors, negligently, carelessly, and/or recklessly breached all duties owed 

to the Plaintiff by permitting the dangerous condition to exist and remain in the bathroom of the 

Premises thereby approximately causing Plaintiff’s serious and permanent injuries.

83. Plaintiff was seriously and permanently injured as a direct and proximate result of 

the negligence, carelessness, and/or reckless acts and/or omissions of Defendant Trump 

Hotels directly and/or by and through its agents, employees, ostensible agents, servants, 

workmen, contractors, subcontractors, and/or representatives, which consisted of the 

following:

a. Failing to properly and adequately inspect the bathroom of the Premises 

to protect against dangerous conditions on the bathroom floor;

b. Failure to correct or remedy a dangerous condition which it knew or 

should have known to be dangerous;

c. Failing to protect individuals lawfully in the bathroom of the Premises, 

including the Plaintiff from the dangerous condition on the bathroom floor 

of the Premises;

d. Failing to warn individuals, including the Plaintiff, of the dangerous 

condition presented by the condition of the bathroom floor;

e. Failing to post warnings, or other symbols in the bathroom of the 

Premises, notifying people of the dangerous condition of the bathroom 

floor;

f. Preventing or allowing a dangerous condition to remain in/on the 

bathroom floor of the Premises;

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32

g. Failing to ensure that the bathroom floor of the Premises was slip 

resistant;

h. Failing to have adequate non-slip protection on the bathroom floor of the 

Premises;

i. Failing to have any bathroom mats or other similar coverings to prevent 

dangerous and slippery conditions on the bathroom floor of the Premises;

j. Failing to properly and adequately construct and/or maintain the floor of 

the bathroom of the Premises in a safe condition;

k. Failing to properly train and instruct the Defendant’s personnel, 

employees, representatives, contractors, subcontractors, and/or agents 

with regard to the proper inspection, maintenance, and/or safety of the 

bathroom floor of the Premises;

l. Failing to ensure that the bathroom floor of the Premises was safely and 

adequately inspected and/or maintained;

m. Failing to obtain an approved plan or design for the inspection, repair, 

and/or maintenance of the bathroom floor of the Premises;

n. Failing to perform an inspection, repairs, and maintenance of the 

bathroom floor of the Premises in accordance with approved plans or 

designs, if any such plans or designs existed;

o. Failing to maintain the bathroom floor in a condition so that it was safe for 

its foreseeable use;

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33

p. Failure to take reasonable steps to ensure that individuals lawfully in the 

bathroom of the Premises including Plaintiff, would remain free from 

unnecessary and reasonable harm;

q. Failing to regularly inspect and maintain the bathroom floor of the 

Premises to ensure that it was maintained and/or remained in a safe 

condition in accordance with the Defendants and/or other appropriate 

policies and procedures;

r. Failing to repair and/or correct the dangerous condition on the bathroom 

floor of the Premises when Defendant knew or should have known that 

such dangerous condition existed;

s. Failing to adopt appropriate policies and/or procedures relating to the 

repair, inspection, maintenance, and/or safety of the bathroom floor of the 

Premises;

t. Failure to properly enforce its policies and/or procedures, if they existed,

relating to the inspection, control, and maintenance of the bathroom floor 

of the Premises;

u. Failing to correct, eliminate, remedy, and/or remove the dangerous 

condition and hazard from the bathroom floor of the Premises;

v. Failure to warn persons, including Plaintiff, of the dangerous condition of 

the bathroom floor of the Premises;

w. Failure to adopt proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, maintenance, and/or safety of the 

bathroom floor of the Premises, and

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34

x. Failure to enforce proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, inspection, maintenance, and/or 

safety of the bathroom floor of the Premises.

84. As a direct and proximate result of the negligent, careless, and/or reckless acts or 

omissions of Defendants, Plaintiff has been severely and permanently injured, as set forth more 

fully in the paragraphs above.

WHEREFORE, Plaintiff, Joan Weiner, demands judgment against Defendants, Trump 

Marina, Trump Marina Associates, L.P., Trump Marina, Inc., Trump Marina Associates, LLC, 

Trump Entertainment, Trump Hotels and John Does 1-10, jointly and severally, for 

compensatory damages, which will reasonably compensate her for her injuries and losses, 

punitive damages, prejudgment and post judgment interests, costs of suit, and any other relief 

deemed equitable and just by this Honorable Court.

COUNT VI – NEGLIGENCE

JOAN WEINER v. JOHN DOES 1-10.

85. Plaintiff hereby incorporates by reference the averments set forth in paragraphs 1 

through 82 inclusive as set forth at length herein.

86. At all times material hereto, Defendant John Does 1-10 directly, by and through 

its employees, agents, workmen, and contractors, owed a duty to Plaintiff and persons in 

Plaintiff’s position to exercise due and ordinary care in the operation of its activities, including 

but not limited to maintenance, inspection, safety, and/or control of the Premises.

87. At all times material hereto, Defendant John Does 1-10 directly, by and through 

its employees, agents, workmen, and contractors, had a duty to make, design, inspect, repair, 

control, and/or maintain the Premises in a reasonable and safe manner.

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35

88. Defendant John Does 1-10 directly, and by and through its employees, agents, 

workmen, and contractors, negligently, carelessly, and/or recklessly breached all duties owed 

to the Plaintiff by permitting the dangerous condition to exist and remain in the bathroom of the 

Premises thereby approximately causing Plaintiff’s serious and permanent injuries.

89. Plaintiff was seriously and permanently injured as a direct and proximate result of 

the negligence, carelessness, and/or reckless acts and/or omissions of Defendant John Does 

1-10 directly and/or by and through its agents, employees, ostensible agents, servants, 

workmen, contractors, subcontractors, and/or representatives, which consisted of the 

following:

a. Failing to properly and adequately inspect the bathroom of the Premises 

to protect against dangerous conditions on the bathroom floor;

b. Failure to correct or remedy a dangerous condition which it knew or 

should have known to be dangerous;

c. Failing to protect individuals lawfully in the bathroom of the Premises, 

including the Plaintiff from the dangerous condition on the bathroom floor 

of the Premises;

d. Failing to warn individuals, including the Plaintiff, of the dangerous 

condition presented by the condition of the bathroom floor;

e. Failing to post warnings, or other symbols in the bathroom of the 

Premises, notifying people of the dangerous condition of the bathroom 

floor;

f. Preventing or allowing a dangerous condition to remain in/on the 

bathroom floor of the Premises;

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36

g. Failing to ensure that the bathroom floor of the Premises was slip 

resistant;

h. Failing to have adequate non-slip protection on the bathroom floor of the 

Premises;

i. Failing to have any bathroom mats or other similar coverings to prevent 

dangerous and slippery conditions on the bathroom floor of the Premises;

j. Failing to properly and adequately construct and/or maintain the floor of 

the bathroom of the Premises in a safe condition;

k. Failing to properly train and instruct the Defendant’s personnel, 

employees, representatives, contractors, subcontractors, and/or agents 

with regard to the proper inspection, maintenance, and/or safety of the 

bathroom floor of the Premises;

l. Failing to ensure that the bathroom floor of the Premises was safely and 

adequately inspected and/or maintained;

m. Failing to obtain an approved plan or design for the inspection, repair, 

and/or maintenance of the bathroom floor of the Premises;

n. Failing to perform an inspection, repairs, and maintenance of the 

bathroom floor of the Premises in accordance with approved plans or 

designs, if any such plans or designs existed;

o. Failing to maintain the bathroom floor in a condition so that it was safe for 

its foreseeable use;

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37

p. Failure to take reasonable steps to ensure that individuals lawfully in the 

bathroom of the Premises including Plaintiff, would remain free from 

unnecessary and reasonable harm;

q. Failing to regularly inspect and maintain the bathroom floor of the 

Premises to ensure that it was maintained and/or remained in a safe 

condition in accordance with the Defendants and/or other appropriate 

policies and procedures;

r. Failing to repair and/or correct the dangerous condition on the bathroom 

floor of the Premises when Defendant knew or should have known that 

such dangerous condition existed;

s. Failing to adopt appropriate policies and/or procedures relating to the 

repair, inspection, maintenance, and/or safety of the bathroom floor of the 

Premises;

t. Failure to properly enforce its policies and/or procedures, if they existed,

relating to the inspection, control, and maintenance of the bathroom floor 

of the Premises;

u. Failing to correct, eliminate, remedy, and/or remove the dangerous 

condition and hazard from the bathroom floor of the Premises;

v. Failure to warn persons, including Plaintiff, of the dangerous condition of 

the bathroom floor of the Premises;

w. Failure to adopt proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, maintenance, and/or safety of the 

bathroom floor of the Premises, and

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38

x. Failure to enforce proper and adequate guidelines, policies, and/or 

procedures relating to the inspection, inspection, maintenance, and/or 

safety of the bathroom floor of the Premises.

90. As a direct and proximate result of the negligent, careless, and/or reckless acts or 

omissions of Defendants, Plaintiff has been severely and permanently injured, as set forth more 

fully in the paragraphs above.

WHEREFORE, Plaintiff, Joan Weiner, demands judgment against Defendants, Trump 

Marina, Trump Marina Associates, L.P., Trump Marina, Inc., Trump Marina Associates, LLC, 

Trump Entertainment, Trump Hotels and John Does 1-10, jointly and severally, for 

compensatory damages, which will reasonably compensate her for her injuries and losses, 

punitive damages, prejudgment and post judgment interests, costs of suit, and any other relief 

deemed equitable and just by this Honorable Court.

JURY DEMAND

PLEASE TAKE NOTICE THAT Plaintiffs hereby demand a trial by jury as to all issues in 

this cause of action. 

CERTIFICATION

I certify that to the best of my personal knowledge, the matter in controversy is not the 

subject of any prior or pending action or arbitration proceeding in any other court, nor is any other 

action or arbitration proceeding contemplated, in that no other party should be joined in this 

action.

I further certify that the forgoing statements made by me are true. I am aware that if any of 

the foregoing statements made by me are willfully false, I am subject to punishment.

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LOCAL CIVIL RULE 11.2 CERTIFICATION

The subject matter of this Complaint is not the subject of any other pending court action, 

arbitration, or administrative proceeding.

SHERIDAN & MURRAY, LLC

BY: /s/ Sean E. Quinn

SEAN E. QUINN, ESQUIRE

Centre Square West, 38th Floor

1500 Market Street

Philadelphia, PA 19102

(215) 977-9500

Attorney for Plaintiff

Dated: December 6, 2010

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