Complaint and Prayer for Jury Trial

IN THE CIRCUIT COURT
FOR BALTIMORE CITY, MARYLAND

MARK MYERS
123 Main Street
Baltimore, Maryland 21218

v.

HOME DEPOT U.S.A., INC.

2455 Paces Ferry Road

Atlanta, Georgia 30339

SERVE ON:

THE CORPORATION TRUST INC.
300 E. Lombard

Baltimore, Maryland 21202

Case No ___________________

COMPLAINT & DEMAND FOR JURY TRIAL

PLAINTIFFS’ COMPLAINT AND JURY DEMAND

Plaintiffs, MARK MYERS and CLEO CARRY, by and through their undersigned attorneys, Ronald V. Miller, Jr. and Miller & Zois, LLC, sues Home Depot, USA, and allege as follows:

1. Plaintiff is a resident of the State of Maryland.
2. Defendant, Home Depot, USA, is a corporation. Defendant’s principal place of business is headquartered in Atlanta, Georgia and which does business throughout the State of Maryland.
3. On February 11, 2012 the Plaintiff was a business invitee at Defendant’s Home Depot, Inc. located at 6315 Eastern Ave, Baltimore, MD 21224
4. Plaintiff was attempting to take down a light fixture from what we now know was an overstocked shelf.
5. Plaintiff suffered a crush injury on his hand. He has permanant tingling and numbness in the hand, along the median, ulnar, and radial nerve. The hand gets and insufficient amont of blood flow. These injures are severe and permanent.
6. Plaintiff’s injuries were due to the negligence of Defendant’s employees who failed to stock the Defendant’s merchandise in a safe and reasonable manner. Defendant’s negligence was the direct and proximate cause of the Plaintiff’s injuries.

WHEREFORE, Plaintiffs demands judgment be entered against the Home Depot, USA for compensatory damages in the full and just amount of ONE MILLION DOLLARS ($1,000,000.00), plus costs, pre-judgment interest, and post- judgment interest