1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
SAMPLE ARIZONA SLIP AND FALL COMPLAINT
LAMBER GOODNOW ATTORNEYS
- 1 -
[LAW FIRM NAME]
[Address]
[City], [State] [ZIP]
[Telephone:]
[Facsimile: ]
[Lawyer Name (Bar No.)]
Email: []
Attorney for Plaintiff
IN THE SUPERIOR COURT OF THE STATE OF ARIZONA
IN AND FOR THE COUNTY OF MARICOPA
Case No.: ____________________________
COMPLAINT
(Tort Non-Motor Vehicle; Premises
Liability)
Tier [1, 2 or 3]
Plaintiff, by and through counsel undersigned, and for [his/her] Complaint against
Defendants, alleges as follows:
PARTIES, JURISDICTION AND VENUE
1. Plaintiff __________ is and was a resident of Maricopa County, Arizona at
all relevant times.
2. Defendant [parent name of retail/business establishment] is now, and at all
times relevant was, a [corporation or other business organization] organized and existing
under the laws of the State of Arizona, with its place of business in Maricopa County,
Arizona.
3. Defendant [parent name of retail establishment] owns, operates and does
business as “[name of retail/business establishment]” located at _____________________,
_________, Arizona, and is in the business of [describe type of business] selling to public.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
SAMPLE ARIZONA SLIP AND FALL COMPLAINT
LAMBER GOODNOW ATTORNEYS
- 2 -
4. At all material times, Defendant includes and included any and all parents,
subsidiaries, affiliates, divisions, franchises, partners, joint ventures, and organization units
of any kind, predecessors, successors and assigns and their officers, directors, employees,
agents, representatives and any and all other persons acting on their behalf.
5. At all material times, each of the Defendant was the agent and employee of
every other Defendant in doing the events described and was at all times acting within the
purpose and scope of such agency and employment and are vicariously liable under the
theory of respondeat superior for the actions and inactions of their employees and
contractors.
6. Defendants John Does and Jane Does 1-10, ABC Corporations 1-10, Limited
Liability Companies and/or partnerships 1-10 are persons and entities whose true identities
are unknown to Plaintiff, who together with named Defendants contributed to causing
Plaintiff’s injuries and damages. Plaintiff will amend [his/her] Complaint when the true
names of those Defendants become known.
7. Jurisdiction and venue are proper as the events giving rise to Plaintiff’s
Complaint occurred in Maricopa County, Arizona and the amount in controversy exceeds
the minimal jurisdictional requirements of this Court.
8. The amount of Plaintiff’s damages qualifies this matter as a Tier [1, 2 or 3]
case in accordance with Rule 8(b)(2) of the Arizona Rules of Civil Procedure.
GENERAL ALLEGATIONS
9. Plaintiff incorporates by reference all prior allegations contained in this
Complaint.
10. On or about _____________, at approximately _____, Plaintiff was on the
premises of Defendant store for the purpose of purchasing various items. After entering the
store, Plaintiff proceeded to the ____________ [aisle/section] when suddenly and without
warning Plaintiff slipped on an unknown substance and fell violently to the floor.
…
…
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
SAMPLE ARIZONA SLIP AND FALL COMPLAINT
LAMBER GOODNOW ATTORNEYS
- 3 -
NEGLIGENCE
11. Plaintiff incorporates by reference all prior allegations contained in this
Complaint.
12. Defendant, as owners and operators of the store, or through its agents or
employees, negligently failed to maintain the floor of the store in a reasonably safe
condition.
13. Defendant, as owners and operators of the store, or through its agents or
employees, allowed a slippery substance to come into contact with and remain on the floor
of the store when Defendant, or its agents or employees, knew, or in the exercise of
reasonable care should have known, that the substance created an unreasonable risk of harm
to customers in the store.
14. Defendant, as owners and operators of the store, or through its agents or
employees, failed to warn Plaintiff of the danger presented by the presence of the slippery
substance on the floor.
15. Defendant failed to provide a nonslip surface on the floor of the store.
16. Defendant failed to otherwise exercise due care with respect to the matters
alleged in this Complaint.
17. As a direct and proximate result of the negligence of Defendants as set forth
above, Plaintiff slipped and fell while in the store.
18. As a further direct and proximate result of the negligence of Defendants set
forth above, Plaintiff sustained serious injuries and damages.
DEMAND FOR JURY TRIAL
19. Plaintiff demands a trial by jury on all issues so triable.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff requests that the Court enter judgment against Defendant
as follows:
A. For Plaintiff’s general and special damages;
B. For Plaintiff’s costs incurred in pursuing these claims;
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
SAMPLE ARIZONA SLIP AND FALL COMPLAINT
LAMBER GOODNOW ATTORNEYS
- 4 -
C. For pre- and post-judgment interest to the extent provided by law;
D. For such further relief as the Court deems just and fair.
DATED this ____ day of _____________, _____.
Respectfully submitted,
[LAW FIRM NAME]
By
[NAME OF ATTORNEY]
[Law Firm Address]
[City] [Arizona], [Zip]
Attorney for Plaintiff