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Actual - Philadelphia- PA Injury Attorney Talks About Pennsylvania Injury Attorney Minor's Injuries
In an injury case involving a slip and fall at a laundromat, the following complaint is a good example of a form you can use. Note that this case involves a minor.
1. Plaintiff, Jammiie Williams is a minor and sues by her parent and natural guardian, James Williams, both of whom reside
1. Plaintiff, Jammiie Williams is a minor and sues by her parent and natural guardian, James Williams, both of whom reside
According to USFDA, a combination product is one composed of any combination of a drug and device; biological product and device; drug and biological product
at the address indicated in the caption.
2. Plaintiff, James Williams is the parent and natural guardian of the minor plaintiff, and brings this action on behalf of Jammiie Williams and in his own right as parent and natural guardian.
3. Defendant, U-Do-It Laundromat a/k/a U-
2. Plaintiff, James Williams is the parent and natural guardian of the minor plaintiff, and brings this action on behalf of Jammiie Williams and in his own right as parent and natural guardian.
3. Defendant, U-Do-It Laundromat a/k/a U-
; or drug, device, and biological product and fixed dose combination would include two or more combinations of drug.
Examples of combination products may in
Examples of combination products may in
o-It Laundry is a business entity licensed to do business in the Commonwealth of Pennsylvania with an address for service of process as indicated in the caption.
4. At all times relevant hereto, defendant acted by and through its agents, servants, workmen, and/or employees, who were
4. At all times relevant hereto, defendant acted by and through its agents, servants, workmen, and/or employees, who were
lude drug-coated devices, drugs packaged with delivery devices in medical kits, and drugs and devices packaged separately but intended to be used together.
acting within the course and scope of their agency, employment and/or authority, and in furtherance of the interest of the defendant.
5. On or about October 17, 2003, and for a long time prior thereto there existed a certain defect, consisting of a puddle of water on the ground and
5. On or about October 17, 2003, and for a long time prior thereto there existed a certain defect, consisting of a puddle of water on the ground and
here is enormous increase in the number of combination products entering the market in the recent years. Combination products have proven advantages but fixe
a leaking washing machine, in the defendant’s laundromat located at 3004 N. 22nd Street, Philadelphia, PA which presented a substantial impediment to travel.
6. The defendant knew or should have known of the said defect sufficiently prior to the said date to take such action as woul
6. The defendant knew or should have known of the said defect sufficiently prior to the said date to take such action as woul
d dose combinations are still in the process of convincing regulatory authority on their advantages over the single ingredient formulations.
Combination pro
Combination pro
cure the said defect.
7. On the date and time aforesaid, defendant had under its care and direction the supervision, control and maintenance of the said laundromat and had the duty to keep it free from defects and safe for travel for those lawfully traversing the said area.
7. On the date and time aforesaid, defendant had under its care and direction the supervision, control and maintenance of the said laundromat and had the duty to keep it free from defects and safe for travel for those lawfully traversing the said area.
ucts have become life saving products for the pharmaceutical companies who doesn’t have many innovative molecules in their product pipeline and have been inc
8. On the said date, the minor plaintiff, was lawfully traversing the said area, at which time she slipped and fell to the ground after she stepped into the said puddle, thereby sustaining certain injuries which are hereafter more particularly set forth.
9. The said accident was t
easingly used in the product life cycle management. Even the companies having product patents are trying to extend their product life cycle through the combi
e result of the defendant's negligence, and was due in no manner whatsoever to any act or failure to act on the part of the plaintiffs.
10. The defendant's negligence consisted of the following:
(a) Allowing the said defect to remain in the said area;
(b) Failing to make
10. The defendant's negligence consisted of the following:
(a) Allowing the said defect to remain in the said area;
(b) Failing to make
nation products and maximize the revenues. But the companies involved in this practice are overlooking that they are burdening the patients both economically
he said area safe for travel for those lawfully upon the said premises;
(c) Failing to maintain the said area and machine in a condition that would protect and safeguard persons lawfully entering the area;
(d) Failing to have the said area and machine inspected at reasonable int
(c) Failing to maintain the said area and machine in a condition that would protect and safeguard persons lawfully entering the area;
(d) Failing to have the said area and machine inspected at reasonable int
and physically. They need to rightly judge the benefits of the combination products and they have to even look at the risks involved when combining the produ
ervals in order to determine its condition;
(e) Failing to warn persons lawfully traversing the said area of the said defect;
(f) Disregarding the rights and safety of the plaintiff at the time she was traversing the said area;
(g) Violating the codes and ordinances of th
(e) Failing to warn persons lawfully traversing the said area of the said defect;
(f) Disregarding the rights and safety of the plaintiff at the time she was traversing the said area;
(g) Violating the codes and ordinances of th
ts. Some of the combination products were well accepted by physicians while others suffered. Companies involved in development of combination products are fi
City of Philadelphia and the statutes of the Commonwealth of Pennsylvania pertaining to property maintenance,
condition of public walkways and provision of safe ingress and egress;
(h) Otherwise filing to use due care under the circumstances, as well may be disclosed during the dis
(h) Otherwise filing to use due care under the circumstances, as well may be disclosed during the dis
ding difficulty in defining their combination products and facing various challenges from selecting a combination to marketing it.
Following aspects would a
Following aspects would a
overy and trial phases of this matter;
COUNT I
JAMES WILLIAMS, Parent and Natural Guardian of JAMMIIE WILLIAMS v. DEFENDANT
11. The allegations contained in paragraphs 1 through 10 above are incorporated by reference as though set forth in full.
12. Solely as the result
COUNT I
JAMES WILLIAMS, Parent and Natural Guardian of JAMMIIE WILLIAMS v. DEFENDANT
11. The allegations contained in paragraphs 1 through 10 above are incorporated by reference as though set forth in full.
12. Solely as the result
dd to the challenges in developing combination products:
Which markets to tap where the combination products can do fairly well?
Which combination prod
Which markets to tap where the combination products can do fairly well?
Which combination prod
of the defendant's negligence, the minor plaintiff sustained severe personal injuries to her head, body, limbs, more particulars, she suffered: aggravation of an ankle fracture, osteoarthritis, shock and injury to her nerves and nervous system, and she was otherwise injured.
13. Al
13. Al
cts are meaningful and rational?
Which therapeutic categories to select?
Which Combinations can address unmet needs of the patients?
Do combin
Which therapeutic categories to select?
Which Combinations can address unmet needs of the patients?
Do combin
the above injuries are serious and permanent except those of a superficial nature. All of the foregoing injuries have rendered the minor plaintiff, sick, sore, lame, prostrate, disabled and disordered and have made her undergo great mental anguish and physical pain, as a result of which
tions increase the patient compliance?
What would be the developing cost?
How to tackle the risks encountered during combination product developmen
What would be the developing cost?
How to tackle the risks encountered during combination product developmen
she has suffered, yet suffers and will continue to suffer for an indefinite time in the future.
14. As a further result of this accident the minor plaintiff, may in the future continue to suffer great pain and agony and may, after her maturity, be indeed and prevented from attending
14. As a further result of this accident the minor plaintiff, may in the future continue to suffer great pain and agony and may, after her maturity, be indeed and prevented from attending
t?
As combination products don't fit into the traditional categories of drugs, medical devices, or biological products, the USFDA is in the process of devel
As combination products don't fit into the traditional categories of drugs, medical devices, or biological products, the USFDA is in the process of devel
to her usual daily work and occupation to her great financial damage and loss.
15. As a further result of this accident the minor plaintiff, has suffered an injury which is in full or part a cosmetic disfigurement which may be permanent, irreparable and severe. WHEREFORE, plai
15. As a further result of this accident the minor plaintiff, has suffered an injury which is in full or part a cosmetic disfigurement which may be permanent, irreparable and severe. WHEREFORE, plai
ping new procedures for reviewing their safety, efficacy and quality.
Professional from academic institutions, pharmaceutical industries, health care indust
Professional from academic institutions, pharmaceutical industries, health care indust
tiff, James Williams, parent and natural guardian of Jammiie Williams, a minor demands judgment against the defendant in an amount not in excess of FIFTY THOUSAND ($50,000.00) DOLLARS plus costs of this suit.
COUNT II
JAMES WILLIAMS v. DEFENDANT
16. The allegations contained i
COUNT II
JAMES WILLIAMS v. DEFENDANT
16. The allegations contained i
y and representatives from various regulatory agencies are working out to design the regulatory requirements for manufacture and sale of combination products
paragraphs 1 through 15 above are incorporated by reference as though set forth in full.
17. As a further result of this accident, the minor plaintiff has been or will be obliged to receive and undergo medical attention and care as the result of which plaintiff, James Williams, has
17. As a further result of this accident, the minor plaintiff has been or will be obliged to receive and undergo medical attention and care as the result of which plaintiff, James Williams, has
.
As there is an increasing trend of the combination products companies manufacturing such products should be able to tackle the problems involved in the de
As there is an increasing trend of the combination products companies manufacturing such products should be able to tackle the problems involved in the de
been required to expend sums of money for medical treatment.
18. As a direct result of the aforesaid accident, James Williams, has or may hereafter incur other financial expenses or losses.
19. As a direct result of the injuries sustained by the minor plaintiff, James William
18. As a direct result of the aforesaid accident, James Williams, has or may hereafter incur other financial expenses or losses.
19. As a direct result of the injuries sustained by the minor plaintiff, James William
elopment. They need to be wiser in analyzing the market trends and the regulatory requirements.
Companies that provide selfless information through particip
Companies that provide selfless information through particip
, has been deprived or may in the future be deprived of the financial assistance, comfort and society of his minor child.
WHEREFORE, plaintiff, James Williams, demands judgment against the defendant in an amount not in excess of FIFTY THOUSAND ($50,000.00) DOLLARS plus costs of this suit
WHEREFORE, plaintiff, James Williams, demands judgment against the defendant in an amount not in excess of FIFTY THOUSAND ($50,000.00) DOLLARS plus costs of this suit
tion in industry events and feedback to regulatory authorities would be able to face the challenges and will be successful in developing combination products
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