COUNT III - Strict Liability-Abnormally Dangerous Activity - Products Liability
Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 12 of this Complaint.
13. Defendant’s conduct in maintaining an electrical system in a public area constituted an abnormally dangerous activity which exposed Plaintiff to an unreasonable risk of harm.
14. At all relevant times, Defendant had control over the abnormally dangerous activity of maintaining the electrical system.
15. As set forth above, Plaintiff sustained injury as a direct and proximate cause of this unreasonably dangerous activity.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of FIVE MILLION DOLLARS ($5,000,000.00), plus interest, costs and any other relief this court deems appropriate.
Respectfully submitted,
MILLER & ZOIS, LLC
Ronald V. Miller, Jr.
Laura G. Zois
Empire Towers, Suite 615
7310 Ritchie Highway
Glen Burnie, Maryland 21061
(410)553-6000
Counsel for Plaintiffs
PLAINTIFF’S REQUEST FOR JURY TRIAL
Plaintiff pursuant to Maryland Rule 2-325, prays a trial by jury on all issues.