Professional Documents
Culture Documents
YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action,
of which a copy is herewith served upon you, and to serve a copy of your answer to the said
Complaint on the subscriber or subscribers at his or their office at Suite 209, The Courtyard,
1500 U.S. Highway 17 North, Post Office Drawer 14547, Surfside Beach, South Carolina 29587
within thirty (30) days after the service hereof; exclusive of the day of such service; and if you
fail to answer the Complaint within the time aforesaid; the Plaintiff in this action will apply to
the Court for the relief demanded in the Complaint and judgment by default will be rendered
The Plaintiff, complaining of the Defendant herein, would show and allege unto this
2. The Plaintiff is informed and believes that the Defendant, Horry County School
District, is a governmental entity organized and existing pursuant to the laws of the State of South
3. That on or about May 5, 2017, the minor Plaintiff was a student at the Defendant
4. That the edge of the desk was razor sharp causing Plaintiff’s injury.
5. That no warnings or signs advised the Plaintiff of this dangerous condition, nor were
there employees at the scene to warn the Plaintiff of the sharp edges of the desk.
6. The Plaintiff is informed and believes that the Defendant, by and through its
agents and/or employees, was negligent, grossly negligent, willful and wanton in one or more of
b. In failing to provide a reasonably safe premises for the use by the Plaintiff;
ELECTRONICALLY FILED - 2018 Dec 07 10:12 AM - HORRY - COMMON PLEAS - CASE#2018CP2606897
c. In stocking desks with sharp edges;
j. In failing to warn the Plaintiff that said premises and desk was in a
dangerous and/or hazardous condition when it knew, or should have
known, of the dangerous and/or hazardous condition;
m. In failing to notify the Plaintiff through its agents and/or employees of the
dangerous and/or hazardous condition existing regarding the desk;
p. In failing to use that degree of skill and care that an ordinary and
reasonable person would have done under similar and like circumstances;
through its agents and/or employees, the Plaintiff has suffered painful and permanent injuries;
has incurred and will continue to incur medical expenses; has suffered and will continue to suffer
pain and discomfort; has suffered and will continue to suffer loss of wages and earning capacity;
has suffered and will continue to suffer a disruption to her daily routine both at home and at
work; and has suffered and will continue to suffer a loss of enjoyment of life.
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ELECTRONICALLY FILED - 2018 Dec 07 10:12 AM - HORRY - COMMON PLEAS - CASE#2018CP2606897
WHEREFORE, the Plaintiff prays for judgment against the Defendant for actual
damages, for punitive damages, for the costs of this action and for such other and further relief as