INADEQUATE SAFETY PROCEDURES BY DADELAND MALL PROPERTY OWNERS RESULT IN PERSONAL INJURY TO MALL EMPLOYEE

The following is a description of a personal injury case we have filed. This is a case involving a personal injury in a parking garage of Dadeland Mall, a property owned by Simon Property Group, Inc.

Dadeland Shopping Mall in Miami-Dade County, Florida is a large shopping complex anchored by high-end retailers and over 185 specialty stores. As such, Dadeland Mall has thousands of shoppers in and around it at any given time carrying money and leaving stores with packages. This provides would be robbers with a large group of targets who are made even more vulnerable by carrying bags and goods in their hands and arms.

Simon Property Group, Inc. knows that because of these circumstances, there is a high number of criminal incidents in which criminals prey on the customers and employees of the stores at the Mall. The rate and number of incidents of these crimes, including assault, battery, robbery, sexual assault, rape, and other crimes against persons are known to Simon Property Group, Inc., managers, owners and security providers of Dadeland Mall, and especially in the parking areas of the mall.

Simon Property Group, Inc. as owners, managers, and security providers are advised by the various tenants, especially anchor tenants and large retailers such as JC Penney, about the changes in rules and regulations of the retailers for the parking of the retailers’ employees.

Dadeland Mall provides for these shoppers parking garages with various degrees of lighting, security patrol and visual security monitoring.

JC Penney had requested that its employees park in a certain level of the parking adjacent to JC Penney and owned, managed and secured by Simon Property Group, Inc.. This level of the parking garage adjacent to JC Penney at Dadeland Mall and owned, managed and secured by Simon Property Group, Inc. had a low and improper lighting level, lack of security cameras, lack of security patrols, and places for assailants to hide in and wait for patrons. Simon Property Group, Inc. knew or should have known of the movements and the activities of the employees of the retailers. Despite the fact Simon Property Group, Inc. knew or should have known of the failure and problems in regard to the less populated levels of the parking garage adjacent to JC Penney, Simon Property Group, Inc. did nothing to rectify the lighting, lack of surveillance, lack of security patrols, architectural details, and other security measures.

As a result of the failures of Simon Property Group, Inc. on February 6, 2007, our client went to JC Penney as an employee and paying customer and while she was in the parking garage adjacent to JC Penney and owned, managed and secured by Simon Property Group, Inc. to drop off her merchandise in her vehicle she was assaulted, battered, and robbed and thrown to the ground. During this assault, our client was struck in the face. Accordingly, as a result of the negligence of Simon Property Group, Inc., our client has suffered and will continue to suffer serious, debilitating, and permanent injuries.