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IN THE CIRCUIT COURT OF THE
NINETEENTH JUDICIAL CIRCUIT
OF FLORIDA, IN AND FOR
ST. LUCIE COUNTY. '
CASE N0. 80-440-CA
DWIGHT BRADLEY,
Plaintiff,
vs.
ATLANTIS CONDOMINIUM BUILDING A
ASSOCIATION and AETNA INSURANCE
COMPANY,
Defendant.
f
AMENDED
C MLA-~F1T
The Plaintiff, DWIGHT BRADLEY, sues the Defendants, ATLANTIS
CONDOMINIUM BUILDING A ASSOCIATION and AETNA INSURANCE COMPANY, and
alleges:
1. This is an action for damages in excess of $2,500.00.
2. At all times material hereto the Defendant, ATLANTIS
CONDOMINIUM BUILDING A ASSOCIATION, hereafter ATLANTIS, was doing
business and owned or controlled the common areas of the ATLANTIS
CONDOMINIUM BUILDING A in St. Lucie County, Florida, and was insured
for public liability by the Defendant, AETNA INSURANCE COMPANY.
i 3. On or about January 3, 1980,_ Plaintiff, as an employee
of Baker Air Conditioning Company, was working on and about the
~ Gammon area of the Defendant, ATLANTIS CONDOMINIUM BUILDING A ASSOCI-
i
' ATION at the invitation of said Defendant.
4. At that time and .place the Plaintiff was not a member
of the Defendant CONDOMINIUM ASSOCIATION nor was he familiar with the
premises.
5. At that time and place the Defendant, CONDOMINIUM
ASSOCIATION, carelessly and negligently maintained the premises and
breached its duty to the Plaintiff to maintain the premises so that
~ it could be used with safety by its patrons i n the following respect:
c
~ a) That the Defendant CONDOMINIUM ASSOCIATION, through
i
~ its agents, servants and employees allowed a defective condition to
be created on its premises, to-wit: a stairway without proper lighting;
i ~
Bl~~t~~'~. PjGE~
~ OSBORNE WALKER O'OUINN - ATTORNEY AT lAW - 201 S. SECOND STREET P. O. BOX 4341 - FORT PIERCE. FLORIDA 33454 - (305) 464-8252