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.
