16-2022-CA-004923-XXXX-MA Div: CV-H Filing # 156087296 E-Filed 08/25/2022 10:42:40 AM. ACCEPTED: DUVAL COUNTY, JODY PHILI IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO.: DIVISION: ANOMOLISA WYNN, as Next Friend of MM., a minor, Plaintiff, vs, KID KINGDOM, LLC, Defendant. I COMPLAINT Plaintiff, ANOMOLISA WYNN, hereby sues Defendant, KID KINGDOM, LLC (hereinafter “KID KINGDOM”), and alleges: ALLEGATIONS COMMON TO ALL COUNTS 1. This is an action for damages that exceeds the sum of THIRTY THOUSAND DOLLARS ($30,000.00), exclusive of costs, interest and attomeys’ fees. 2. Atalll times material hereto, including all dates of incidence referred to herein, Plaintiff, ANOMOLISA WYNN, and minor M.M., were residents of Duval County, Florida. 3. Atall times material hereto, including all dates of incidence referred to herein, Plaintiff M.M., was one year of age. 4, Atall times material hereto, including all dates of incidence referred to herein, Defendant, KID KINGDOM, was, and remains, a Florida Limited Liability Company. 5. Atalll times material hereto, including all dates of incidence referred to herein, Defendant, KID KINGDOM, operated a child care facility located at 8720 Collins Road, Jacksonville, Duval County, Florida (“subject childcare facility”). IPS, CLERK. 08/26/2022 08:26:41 AM.6. Atall times material hereto, each Defendant herein was regulated under Florida Statutes, Florida Administrative Code, and requirements and guidelines published by the Florida Department of Children and Families, including the Florida Department of Children and Families Child Care Facility Handbook. 7. Atal times material hereto, including all dates of incidence referred to herein, Defendant, KID KINGDOM, as the owner/operator of the subject childcare facility, was responsible for the care and safety of children placed in their subject childcare facility, including Plaintiff M.M., and owed Plaintiff M.M., a duty to take reasonable measures to prevent injury such as that which occurred. 8 At all times relevant to this cause of action, Defendant, KID KINGDOM, individually and by and through its employees, agents and affiliates, had a duty to provide a safe subject childcare facility and safe childcare services to Plaintiff M.M., while she was present and enrolled at Defendant's subject childcare facility. COUNT I: NEGLIGENCE CAUSING AND CONTRIBUTING TO INJURY OF D [BER 20, 2021 9. Plaintiff hereby incorporates and re-alleges paragraphs one (1) through eight (8), and further alleges as follows: 10. Defendant, KID KINGDOM, individually and by and through its employees, agents and affiliates, breached its duty of care to the Plaintiff M.M. through the following actions or inactions: a. negligently failing to properly care for, observe, and supervise Plaintiff M.M., appropriately for her age; b. negligently causing injury to Plaintiff M.M. due to failing to properly supervise the Plaintiff M.M., thus creating an unreasonably dangerous condition for Plaintiff M.M.c. negligently failing to provide a safe subject childcare facility with adequate supervision of young children; 4. negligently failing to adequately staff the classrooms at the facility such that the children, including Plaintiff M.M., were not properly supervised; e. negligently hiring and retaining unqualified persons to staff the classrooms at the subject childcare facility such that the staffing of the subject childcare facility created an unreasonably dangerous condition for Plaintiff M.M.; £ negligently failing to take corrective action to reduce the frequency of injury in the classroom of Plaintiff M.M.; g permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility; h permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility to the point of intoxication; i. negligently failing to timely notice the injuries sustained by Plaintiff MM. and take immediate action to notify the parents of Plaintiff M.M. of said injuries; and j. otherwise failing to exercise due care with regard to the matters contained herein, 11, Asa result of the above, on December 20, 2021, while Plaintiff M.M. was under Defendant’s custody and care, at the subject childcare facility owned by Defendant, Plaintiff M.M. sustained injury to her lip and mouth. 12. The negligent condition of the subject childcare facility and staffing inadequacies were known by Defendant, KID KINGDOM, as having been created by said Defendant, or had existed for a sufficient length of time so that Defendant should have known of same. 13. As a direct and proximate result of the negligence of Defendant, Plaintiff M.M. suffered bodily injury in and about her body and extremities, resulting in pain and suffering, disability, disfigurement, permanent and significant scarring, mental anguish, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of previously existing condition. The losses are either permanent or continuing andPlaintiff will suffer the losses in the future. WHEREFORE, Plaintiff, ANOMOLISA WYNN as Mother and Next Friend of M.M., a minor, sues Defendant, KID KINGDOM, for damages, plus interest and costs and other such relief deemed proper by the Court. COUNT NEGLIGENCE CAUSING AND CONTRIBUT AANUARY 3, 2022 14, Plaintiff hereby incorporates and re-alleges paragraphs one through eight, and further alleges as follows: 15. Defendant, KID KINGDOM, individually and by and through its employees, agents and affiliates, breached its duty of care to the Plaintiff M.M. through the following actions or inactions: a. negligently failing to properly care for, observe, and supervise Plaintiff M.M. appropriately for her age; b. negligently causing injury to Plaintiff MM. due to failing to properly supervise the Plaintiff MM., thus creating an unreasonably dangerous condition for Plaintiff MM. negligently failing to provide a safe subject childcare facility with adequate supervision of young children; 4. negligently failing to adequately staff the classrooms at the facility such that the children, including Plaintiff M.M., were not properly supervised; e. negligently hiring and retaining unqualified persons to staff the classrooms at the subject childcare facility such that the staffing of the subject childcare facility created an unreasonably dangerous condition for Plaintiff MM.; £ negligently failing to take corre the classroom of Plaintiff M.M.; action to reduce the frequency of injury in permitting or negligently permitting staff to consume alcohol while on duty and at the subject childeare facility; h. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility to the point of intoxication;i, negligently failing to timely notice the injuries sustained by Plaintiff’ MM. and take immediate action to notify the parents of Plaintiff M.M. of said injuries; and, J. otherwise failing to exercise due care with regard to the matters contained herein 16. As a result of the above, on January 3, 2022, while Plaintiff M.M. was under Defendant's custody and care, at the subject childcare facility owned by Defendant, Plaintiff MM sustained injury to her eye. 17, The negligent condition of the subject childcare facility and staffing inadequacies were known by Defendant, KID KINGDOM, as having been created by said Defendant, or had existed for a sufficient length of time so that Defendant should have known of same. 18. As a direct and proximate result of the negligence of Defendant, Plaintiff M.M. suffered bodily injury in and about her body and extremities, resulting in pain and suffering, disability, disfigurement, permanent and significant scarring, mental anguish, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of previously existing condition. ‘The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. WHEREFORE, Plaintiff, ANOMOLISA WYNN as Mother and Next Friend of MM., a minor, sues Defendant, KID KINGDOM, for damages, plus interest and costs and other such relief deemed proper by the Court. COUNT II: EGLIGENCE CAUSING AND CONTRIBUTING TO INJURY OF MARCH 9, 2022 19. Plaintiff hereby incorporates and re-alleges paragraphs one through eight, and further alleges as follows: 20. Defendant, KID KINGDOM, individually and by and through its employees, agents and affiliates, breached its duty of care to the Plaintiff M.M. through the following actionsor inactions: 21. a, negligently failing to properly care for, observe, and supervise Plaintiff M.M., appropriately for her age; b. negligently causing injury to Plaintiff MM. due to failing to properly supervise the Plaintiff M.M., thus creating an unreasonably dangerous condition for Plaintiff MM. ©. negligently failing to provide a safe subject childcare facility with adequate supervision of young children; 4. negligently failing to adequately staff the classrooms at the facility such that the children, including Plaintiff M.M., were not properly supervised; e. negligently hiring and retaining unqualified persons to staff the classrooms at the subject childcare facility such that the staffing of the subject childcare facility created an unreasonably dangerous condition for Plaintiff M.M.; £ negligently failing to take corrective action to reduce the frequency of injury in the classroom of Plaintiff MM. g. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility; h. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility to the point of intoxication; i. negligently failing to timely notice the injuries sustained by Plaintiff MM. and take immediate action to notify the parents of Plaintiff M.M. of said injuries; and, otherwise failing to exercise due care with regard to the matters contained herein, As a result of the above, on March 9, 2022, while Plaintiff M.M. was under Defendant's custody and care, at the subject childcare facility owned by Defendant, Plaintiff M.M. sustained injury to her forehead. 22. were known by Defendant, KID KINGDOM, as having been created by s The negligent condition of the subject childcare facility and staffing inadequacies Defendant, or had existed for a sufficient length of time so that Defendant should have known of same. 23. As a direct and proximate result of the negligence of Defendant, Plaintiff MM.suffered bodily injury in and about her body and extremities, resulting in pain and suffering, disability, disfigurement, permanent and significant scarring, mental anguish, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of previously existing condition. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. WHEREFORE, Plaintiff, ANOMOLISA WYNN as Mother and Next Friend of MM., a minor, sues Defendant, KID KINGDOM, for damages, plus interest and costs and other such relief deemed proper by the Court. COUNT IV: NEGLIGENCE CAUSING AND CONTRIBUTING TO INJURY OF MARCH 10, 2022 24. Plaintiff hereby incorporates and re-alleges paragraphs one through eight, and further alleges as follows: 25. Defendant, KID KINGDOM, individually and by and through its employees, agents and affiliates, breached its duty of care to the Plaintiff M.M. through the following actions or inactions a. negligently failing to properly care for, observe, and supervise Plaintiff M.M., appropriately for her age; b. negligently causing injury to Plaintiff MM. due to failing to properly supervise the Plaintiff MM., thus creating an unreasonably dangerous condition for Plaintiff MM. c. negligently failing to provide a safe subject childcare facility with adequate supervision of young children; 4. negligently failing to adequately staff the classrooms at the facility such that the children, including Plaintiff M.M., were not properly supervised; €. negligently hiring and retaining unqualified persons to staff the classrooms at the subject childcare facility such that the staffing of the subject childcare facility created an unreasonably dangerous condition for Plaintiff M.M.;negligently failing to take corrective action to reduce the frequency of injury in the classroom of Plaintiff M.M.; g. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility h, permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility to the point of intoxication; i. negligently failing to timely notice the injuries sustained by Plaintiff MM. and take immediate action to notify the parents of Plaintiff M.M. of said injuries; and J. otherwise failing to exercise due care with regard to the matters contained herein, 26. Asa result of the above, on March 10, 2022, while Plaintiff M.M. was under Defendant’s custody and care, at the subject childcare facility owned by Defendant, Plaintiff M.M. sustained injury to the back of her head. 27. The negligent condition of the subject childcare facility and staffing inadequacies were known by Defendant, KID KINGDOM, as having been created by said Defendant, or had existed for a sufficient length of time so that Defendant should have known of same. 28. Asa direct and proximate result of the negligence of Defendant, Plaintiff’ M.M. suffered bodily injury in and about her body and extremities, resulting in pain and suffering, disabilit , disfigurement, permanent and significant scarring, mental anguish, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of previously existing condition. ‘The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. WHEREFORE, Plaintiff, ANOMOLISA WYNN as Mother and Next Friend of MM, a minor, sues Defendant, KID KINGDOM, for damages, plus interest and costs and other such relief deemed proper by the Court.COUNT V: NEGLIGENCE CAUSING AND CONTRIBUT 29. TO INJURY OF MARCH 15, 2022 Plaintiff hereby incorporates and re-alleges paragraphs one through eight, and further alleges as follows: 30. Defendant, KID KINGDOM, individually and by and through its employees, agents and affiliates, breached its duty of care to the Plaintiff M.M. through the following actions or inactions: 31. a negligently failing to properly care for, observe, and supervise Plaintiff M.M., appropriately for her age; b. negligently causing injury to Plaintiff MM. due to failing to properly supervise the Plaintiff MM., thus creating an unreasonably dangerous condition for Plaintiff MM. negligently failing to provide a safe subject childcare facility with adequate supervision of young children; 4. negligently failing to adequately staff the classrooms at the facility such that the children, including Plaintiff M.M., were not properly supervised; e. negligently hiring and retaining unqualified persons to staff the classrooms at the subject childcare facility such that the staffing of the subject childcare facility created an unreasonably dangerous condition for Plaintiff MM.; £ negligently failing to take corre the classroom of Plaintiff M.M.; action to reduce the frequency of injury in permitting or negligently permitting staff to consume alcohol while on duty and at the subject childeare facility; h. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility to the point of intoxication; i, negligently failing to timely notice the injuries sustained by Plaintiff MM. and take immediate action to notify the parents of Plaintiff M.M. of said injuries; and J. otherwise failing to exercise due care with regard to the matters contained herein, As a result of the above, on March 15, 2022, while Plaintiff M.M. was underDefendant's custody and care, at the subject childcare facility owned by Defendant, Plaintiff M.M. sustained injury to her eye. 32, The negligent condition of the subject childcare facility and staffing inadequacies were known by Defendant, KID KINGDOM, as having been created by said Defendant, or had existed for a sufficient length of time so that Defendant should have known of same. 33. As a direct and proximate result of the negligence of Defendant, Plaintiff M.M. suffered bodily injury in and about her body and extremities, resulting in pain and suffering, disability, disfigurement, permanent and significant scarring, mental anguish, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of previously existing condition. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. WHEREFORE, Plaintiff, ANOMOLISA WYNN as Mother and Next Friend of M.M., a minor, sues Defendant, KID KINGDOM, for damages, plus interest and costs and other such relief deemed proper by the Court. COUNT VI: NEGLIGENCE CAUSING AND CONTRIBUTING TO INJURY OF MARCH 22, 2022 34. Plaintiff hereby incorporates and re-alleges paragraphs one through eight, and further alleges as follows: 35. Defendant, KID KINGDOM, individually and by and through its employees, agents and affiliates, breached its duty of care to the Plaintiff M.M. through the following actions or inactions: a. negligently failing to properly care for, observe, and supervise Plaintiff M.M., appropriately for her age; b. negligently causing injury to Plaintiff M.M. due to failing to properly supervise the Plaintiff M.M., thus creating an unreasonably dangerous condition for Plaintiff M.M.; 10c. negligently failing to provide a safe subject childcare facility with adequate supervision of young children; 4. negligently failing to adequately staff the classrooms at the facility such that the children, including Plaintiff M.M., were not properly supervised; e. negligently hiring and retaining unqualified persons to staff the classrooms at the subject childcare facility such that the staffing of the subject childcare facility created an unreasonably dangerous condition for Plaintiff M.M.; £ negligently failing to take corrective action to reduce the frequency of injury in the classroom of Plaintiff M.M.; g permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility; h, permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility to the point of intoxication; i. negligently failing to timely notice the injuries sustained by Plaintiff MM. and take immediate action to notify the parents of Plaintiff M.M. of said injuries; and, j. otherwise failing to exercise due care with regard to the matters contained herein, 36. As a result of the above, on March 22, 2022, while Plaintiff M.M. was under Defendant’s custody and care, at the subject childcare facility owned by Defendant, Plaintiff M.M. sustained injury to her chin. 37. The negligent condition of the subject childcare facility and staffing inadequacies were known by Defendant, KID KINGDOM, as having been created by said Defendant, or had existed for a sufficient length of time so that Defendant should have known of same, 38. Asa direct and proximate result of the negligence of Defendant, Plaintiff’ M.M. suffered bodily injury in and about her body and extremities, resulting in pain and suffering, disability, disfigurement, permanent and significant scarring, mental anguish, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of previously existing condition. The losses are either permanent or continuing and WPlaintiff will suffer the losses in the future. WHEREFORE, Plaintiff, ANOMOLISA WYNN as Mother and Next Friend of MM., a minor, sues Defendant, KID KINGDOM, for damages, plus interest and costs and other such relief deemed proper by the Court. COUNT VII: NEGLIGENCE CAUSING AND CONTRIB! MARCH 25, 2022 ING TO INJURY OF 39. Plaintiff hereby incorporates and re-alleges paragraphs one through eight, and further alleges as follows: 40. Defendant, KID KINGDOM, individually and by and through its employees, agents and affiliates, breached its duty of care to the Plaintiff M.M. through the following actions or inactions: a negligently failing to properly care for, observe, and supervise Plaintiff M.M., appropriately for her age; b. negligently causing injury to Plaintiff M.M. due to failing to properly supervise the Plaintiff M.M., thus creating an unreasonably dangerous condition for Plaintiff M.M negligently failing to provide a safe subject childcare facility with adequate supervision of young children; 4. negligently failing to adequately staff the classrooms at the facility such that the children, including Plaintiff M.M., were not properly supervised; e. negligently hiring and retaining unqualified persons to staff the classrooms at the subject childcare facility such that the staffing of the subject childcare facility created an unreasonably dangerous condition for Plaintiff M.M.; £, negligently failing to take corrective action to reduce the frequency of injury in the classroom of Plaintiff M.M.; g. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility; h. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility to the point of intoxication; 12i. negligently failing to timely notice the injuries sustained by Plaintiff M.M. and take immediate action to notify the parents of Plaintiff M.M. of said injuries; and, J. otherwise failing to exercise due care with regard to the matters contained herein, 41. As a result of the above on March 25, 2022, while Plaintiff M.M. was under Defendant's custody and care, at the subject childcare facility owned by Defendant, Plaintiff MM sustained injury to her face. 42. The negligent condition of the subject childcare facility and staffing inadequacies were known by Defendant, KID KINGDOM, as having been created by said Defendant, or had existed for a sufficient length of time so that Defendant should have known of same. 43. As a direct and proximate result of the negligence of Defendant, Plaintiff M.M. suffered bodily injury in and about her body and extremities, resulting in pain and suffering, disability, disfigurement, permanent and significant scarring, mental anguish, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of previously existing condition. ‘The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. WHEREFORE, Plaintiff, ANOMOLISA WYNN as Mother and Next Friend of MM., a minor, sues Defendant, KID KINGDOM, for damages, plus interest and costs and other such relief deemed proper by the Court. COUNT VIII: NEGLIGENCE CAUSING AND CONTRIBUTING TO INJURY OF APRIL 21, 2022 44, Plaintiff hereby incorporates and re-alleges paragraphs one through eight, and further alleges as follows: 45. Defendant, KID KINGDOM, individually and by and through its employees, agents and affiliates, breached its duty of care to the Plaintiff M.M. through the following actions 1Bor inactions: 46. a, negligently failing to properly care for, observe, and supervise Plaintiff M.M., appropriately for her age; b. negligently causing injury to Plaintiff M.M. due to failing to properly supervise the Plaintiff M.M., thus creating an unreasonably dangerous condition for Plaintiff M.M.; ©. negligently failing to provide a safe subject childcare facility with adequate supervision of young children; 4. negligently failing to adequately staff the classrooms at the facility such that the children, including Plaintiff M.M., were not properly supervised; e. negligently hiring and retaining unqualified persons to staff the classrooms at the subject childcare facility such that the staffing of the subject childcare facility created an unreasonably dangerous condition for Plaintiff M.M. £ negligently failing to take corrective action to reduce the frequency of injury in the classroom of Plaintiff M.M.; g. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility; h. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility to the point of intoxication; i. negligently failing to timely notice the injuries sustained by Plaintiff M.M. and take immediate action to notify the parents of Plaintiff MM. of said injuries; and, otherwise failing to exercise due care with regard to the matters contained herein. As a result of the above, on April 21, 2022, while Plaintiff M.M. was under Defendant's custody and care, at the subject childcare facility owned by Defendant, Plaintiff M.M. sustained injury to her head. 47. were known by Defendant, KID KINGDOM, as having been created by s The negligent condition of the subject childcare facility and staffing inadequacies Defendant, or had existed for a sufficient length of time so that Defendant should have known of same. 48. As a direct and proximate result of the negligence of Defendant, Plaintiff MM. 4suffered bodily injury in and about her body and extremities, resulting in pain and suffering, disability, disfigurement, permanent and significant scarring, mental anguish, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of previously existing condition. The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. WHEREFORE, Plaintiff, ANOMOLISA WYNN as Mother and Next Friend of MM., a minor, sues Defendant, KID KINGDOM, for damages, plus interest and costs and other such relief deemed proper by the Court. COUNT 1X: NEGLIGENCE CAUSING AND CONTRIBUTING TO INJURY OF SULY 14, 2022 49. Plaintiff hereby incorporates and re-alleges paragraphs one through eight, and further alleges as follows: 50. Defendant, KID KINGDOM, individually and by and through its employees, agents and affiliates, breached its duty of care to the Plaintiff M.M. through the following actions or inactions a. negligently failing to properly care for, observe, and supervise Plaintiff M.M., appropriately for her age; b. negligently causing injury to Plaintiff M.M. due to failing to properly supervise the Plaintiff M.M., thus creating an unreasonably dangerous condition for Plaintiff M.M.; c. negligently failing to provide a safe subject childcare facility with adequate supervision of young children; 4. negligently failing to adequately staff the classrooms at the facility such that the children, including Plaintiff M.M., were not properly supervised; €. negligently hiring and retaining, unqualified persons to staff the classrooms at the subject childcare facility such that the staffing of the subject childcare facility created an unreasonably dangerous condition for Plaintiff MM.; 15negligently failing to take corrective action to reduce the frequency of injury in the classroom of Plaintiff M.M.; g. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility; h. permitting or negligently permitting staff to consume alcohol while on duty and at the subject childcare facility to the point of intoxication; i. negligently failing to timely notice the injuries sustained by Plaintiff M.M. and take immediate action to notify the parents of Plaintiff M.M. of said injuries; and, J. otherwise failing to exercise due care with regard to the matters contained herein. 51. As a result of the above, on July 14, 2022, while Plaintiff M.M. was under Defendant’s custody and care, at the subject childcare facility owned by Defendant, Plaintiff M.M. sustained injury to her face. 52. The negligent condition of the subject childcare facility and staffing inadequacies were known by Defendant, KID KINGDOM, as having been created by said Defendant, or had existed for a sufficient length of time so that Defendant should have known of same. 53. Asa direct and proximate result of the negligence of Defendant, Plaintiff’ M.M. suffered bodily injury in and about her body and extremities, resulting in pain and suffering, disability, disfigurement, permanent and significant scarring, mental anguish, loss of the capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, and aggravation of previously existing condition. ‘The losses are either permanent or continuing and Plaintiff will suffer the losses in the future. WHEREFORE, Plaintiff, ANOMOLISA WYNN as Mother and Next Friend of MM., a minor, sues Defendant, KID KINGDOM, for damages, plus interest and costs and other such f deemed proper by the Court. 16Plaintiff demands trial by jury of all issues so triable. RESPECTFULLY submitted this 25" day of August, 202: MORGAN & MORGAN, P.A. /s/ Sarah A. Foster SARAH A. FOSTER, ESQUIRE FL Bar No.: 0115462 76 South Laura Street, Suite 1100 Jacksonville, Florida 32202 Telephone: (904) 361-4442 Facsimile: (904) 361-7242 Primary: sarahfoster@forthepeople.com Secondary: vharrison@forthepeople.com Secondary: Iperez@forthepeople.com Attorney for Plaintiff 7