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COUNT II - Negligent Design and/or Maintenance - Product Liability
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- COUNT III - Strict Liability-Abnormally Dangerous Activity - Products Liability
| COUNT II - Negligent Design and/or Maintenance - Product Liability
Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 9 of this Complaint. 10. Defendant built and/maintained an electrical system that had a defective design or was defectively maintained. Accordingly, defendant owed a duty to Plaintiff that the system was designed and maintained in such a way that made the system safe for its intended purpose. 11. Defendant knew or should have known when building and maintaining this electrical system that it was designed defectively or maintained, creating an unreasonable risk of injury to Plaintiff. 12. Plaintiff was negligent in failing to properly design, manufacture, install, maintain, and communicate the defect in the system to Plaintiff, creating a clear and immediate risk of serious injury. As a direct and proximate result, Plaintiff sustained serious injury. COUNT III - Strict Liability-Abnormally Dangerous Activity - Products Liability Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 12 of this Complaint. 13. Defendant’s conduct in maintaining an electrical system in a public area constituted an abnormally dangerous activity which exposed Plaintiff to an unreasonable risk of harm. 14. At all relevant times, Defendant had control over the abnormally dangerous activity of maintaining the electrical system. 15. As set forth above, Plaintiff sustained injury as a direct and proximate cause of this unreasonably dangerous activity. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of FIVE MILLION DOLLARS ($5,000,000.00), plus interest, costs and any other relief this court deems appropriate. Respectfully submitted, MILLER & ZOIS, LLC Ronald V. Miller, Jr. Laura G. Zois Empire Towers, Suite 615 7310 Ritchie Highway Glen Burnie, Maryland 21061 (410)553-6000 Counsel for Plaintiffs PLAINTIFF’S REQUEST FOR JURY TRIAL Plaintiff pursuant to Maryland Rule 2-325, prays a trial by jury on all issues. жүктеу/скачать 3,06 Mb. Достарыңызбен бөлісу:
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