At all times material hereto, Defendant Miranda Pallone was the owner and Registered Agent of Posh Maids, LLC and was a resident of Colorado, County of Denver, with a Registered AgentStreet address of 1742 Champa Street, #3D, Denver, CO 80202 and a mailing address of P.O.Box 3216, Denver, CO 80201.
At all times material hereto, Defendant Does were unknown agents and/or employees of PoshMaids, LLC.
All of the events alleged herein occurred within the State of Colorado, and all the parties areresidents in the state of Colorado or operate a business in the State of Colorado.
Venue is proper in the District Court for Denver County, as all acts complained of occurredherein, Plaintiff resides in Denver County, and Defendants operate a business in Denver County.
III. FACTUAL ALLEGATIONS
Plaintiff hereby incorporates by reference as though fully set forth herein the allegationscontained in the General Allegations of the Complaint.
Plaintiff was the owner of Ruthie, an 18-month-old dog of
In 2011, Plaintiff engaged the services of Defendant Posh Maids after purchasing a “LivingSocial” coupon, which entitled her to three hours of housecleaning for $49.00. Plaintiff scheduled the housecleaning appointment for August 17, 2011.
On August 17, 2011, Defendant Posh Maids arrived at Plaintiff’s house at approximately 10:00AM.
Upon the arrival of Defendant Posh Maids, Plaintiff asked one of the maids, named “Tina,” if she could leave the dog Ruthie at the home while Plaintiff ran errands. “Tina” stated thatleaving Ruthie at the house would be fine.
Plaintiff instructed “Tina” that if she needed to leave the house for any reason, she must only usethe back door because it was the only door to the house could be locked without a key. The back door was attached to a mudroom, which was enclosed by a second door that led to the kitchen.The presence of the second door prevented Ruthie from leaving the house.