JAYNE A KILLIAN -VS- LAKES EDGE APARTMENTS LLC

owner in possession and in control of that certain premises located at Plantation Lakes Cir, Sanford, FL .

5. On December 12, 2024 , Plaintiff visited Defendant's premises to visit her daughter who was a lawful tenant. As Plaintiff was walking down the set of stairs at the apartment complex located near apartment , the stairs collapsed, causing Plaintiff to sustain significant personal injuries.

Plaintiff realleges and incorporates herein by reference paragraphs 1 through 4 above and further states:

6. At said time and place, Plaintiff was lawfully upon Defendant's premises as a business invitee.

7. Defendant owed Plaintiff a non-delegable duty to (1) maintain the premises in a reasonably safe condition; and (2) warn of any dangerous conditions about which it knew or should have known about. See Florida Dept. of Natural Resources V. Garcia, 753 So. 2d 72 (Fla. 2000 ).

8. Defendant, breached its non-delegable duty owed to Plaintiff by (1) negligently failing to maintain the premises in a reasonably safe condition, (2) negligently failing to correct a dangerous condition about which the defendant either knew or should have known, by the use of reasonable care, and (3) negligently failing to warn the plaintiff of a dangerous condition about

which the defendant had, or should have had knowledge greater than that of the plaintiff. See Fla.

Std. Jury Instr. (Civ.) 401.20(a)

9. As a direct and proximate result of Defendant's negligence, Plaintiff suffered:

a) Bodily and terminal injury including a permanent injury to her body as a whole.

b) Pain and suffering of both a physical and mental nature.

c) Disability, physical impairment, disfigurement, mental anguish, inconvenience.

d) Loss of capacity for the enjoyment of life.

e) Aggravation of an existing condition.

f) Expense of hospitalization, medical and nursing care and treatment.

g) Past lost wages, loss of earning power, diminished earning capacity.

h) Loss of ability to lead and enjoy a normal life.

i) Losses are permanent or continuing and Plaintiff will suffer in the future.

Wherefore Plaintiff demands judgment for damages against Defendant and trial by jury.

Plaintiff realleges and incorporates herein by reference paragraphs 1 through 4 above and further states:

10. At said time and place, Plaintiff was lawfully upon Defendant's premises as a business invitee.

11. Defendant owed Plaintiff a non-delegable duty to (1) maintain the premises in a reasonably safe condition; and (2) warn of any dangerous conditions about which it knew or should have known about. See Florida Dept. of Natural Resources V. Garcia, 753 So. 2d 72 (Fla. 2000 ).

12. Defendant, breached its non-delegable duty owed to Plaintiff by (1) negligently failing to maintain the premises in a reasonably safe condition, (2) negligently failing to correct a