DOWNES v. J.C. PENNEY CO. The following is a description of a personal injury case we have filed. This is a case involving a personal injury caused by a slip and fall inside of a J.C. Penney store. On or about August 4, 1999, our client, Ms. Downes, in the J.C. Penney store in Westland Mall, doing business at 1655 W. 49th St. in Hialeah, Florida, slipped and fell on a wet floor. J.C. Penney failed to provide any or sufficient warning that the floor was wet. Ms. Downes fell, injuring her right knee. J.C. Penney breached its duty to reasonably clean and maintain the premises. J.C. Penney was negligent by failing to keep the floor clean and dry to allow normal and safe foot traffic, failing to clean or mop spills or leaks during hours when people were present on the premises, failing to post signs warning that the floor was wet, among other things. The negligent condition was created by J.C. Penney, or was known to J.C. Penney, or had existed for a sufficient length of time so that J.C. Penney should have known of it. As a result of J.C. Penney’s negligence, our client, Ms. Downes, was injured in and about her body and extremities, suffered pain therefrom, incurred medical expenses in the treatment of the injuries, and suffered physical handicap, and her working ability is impaired. As a result, our client, Ms. Downes, has suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings, and loss of ability to earn money. The losses are either permanent or continuing and Ms. Downes will suffer the losses in the future. We are fighting… for the safety and security of you and your family. Making cruise lines, other commercial facilities, and products safer and more secure, one case at a time. Call us today. All consultations are free and strictly confidential. TOLL FREE: 1.800.215.7117. See our website for information on what to do in the event of an injury on a cruise ship: www.hickeylawfirm.com. See also www.cruiseshipassault.com. The bottom line is get medical care immediately, take photos of the area where you were injured, get the names and contact information of witnesses, and report the accident or incident at once. Also, CALL HICKEY LAW FIRM, P.A., TOLL FREE AT: 1.800.215.7117. Our consultations are always free. We work on a contingency fee basis; if we don’t recover, you don’t pay. Personal injury, wrongful death, sexual assaults, and medical malpractice. This all happens on cruise ships and we have handled these types of claims for 29 years. If you have been injured on another person’s property or a commercial property as a result of negligence or wrongdoing, you may have a premises liability case. To schedule a free consultation in the Miami area with a premises liability attorney, contact our Florida law firm today. John H. (Jack) Hickey has the experience and wherewithal you are seeking and can help protect your rights. OUR MISSION is to provide to you, the honest, seriously injured person, the advice you need, the representation you want, and the compensation you deserve. By doing this, we correct unsafe places, procedures, conditions, and products on cruise ships, stores, commercial facilities, at work, and at home. Representing honest seriously injured people in cases of personal injury, wrongful death, cruise ship accidents, maritime accidents, boating accidents, aviation and airplane crashes, slip and falls, trip and falls, car accidents, truck accidents, product liability, medical malpractice, professional negligence, wrongful prescriptions, sexual assault, assault and battery, and negligent security. We represent these people in cases where they have suffered wrongful death or injuries with permanent impairments or disabilities such as orthopedic injuries which include broken bones or torn ligaments or tendons, injuries to the organs, neurological injuries, head and brain injuries, burn injuries, psychological injuries from trauma, or scarring and disfigurement. Hickey Law Firm, P.A. is headed up by John H. (Jack) Hickey. Hickey was born and raised in the cruise line capital of the world, Miami, Florida. For the first 17 years of his career, Hickey represented the cruise lines and insurance companies. Now he represents you, the seriously injured, the family of a loved one who has died as a result of someone else’s negligence, the victim of a sexual assault, or the victim of medical malpractice. Hickey has testified before Congress about safety and security onboard cruise ships and claims against cruise lines. He is Board Certified as a Civil Trial Lawyer by The Florida Bar and by the National Board of Trial Advocacy. He is a Past President of the Dade County Bar Association. He currently serves on the Board of Governors of The Florida Bar. Hickey has been named by his peers as a “SUPERLAWYER” in the Superlawyer.com publication (the top 5% of all lawyers); as a “Top Lawyer in South Florida” in the areas of personal injury and maritime in the South Florida Legal Guide (2004 to present); and as a “Legal Elite” member in Florida Trend Magazine (2006) (top 1.7% of all lawyers). He is listed in Who’s Who in America, Who’s Who in American Law, and Who’s Who in Emerging Leaders in America. Hickey is rated A/V by Martindale Hubbell, the international directory of lawyers, a rating achieved by only 5% of all attorneys. CONTACT US AND SEE OUR RESULTS AT: www.hickeylawfirm.com and CALL US TOLL FREE AT 1.800.215.7117.