NEW ORLEANS - After tripping and falling over broken concrete at a K Mart store in Mandeville, Valerie Dragon has filed suit in federal court in New Orleans.

The alleged incident occurred on April 4, 2011 as Dragon was leaving the store and pushing her shopping cart. She claims she tripped and fell due to broken and fragmented concrete in the front of the store.

She sustained a broken nose and other injuries, the suit claims.

The defendant is accused of negligence for allegedly failing to use reasonable care in maintaining the front of the store, failing to properly protect patrons from injury caused dangerous and defective broken and fragmented concrete, failing to repair the dangerous and defective broken and fragmented concrete, failing to properly maintain the front of the store, failing to establish proper procedures for maintaining the front of the store, and for creating or having actual or constructive notice of the condition which caused Dragon's injury.

The plaintiff is asking the court for an award of damages for pain, disability, medical expenses, pain and suffering, emotional damages, interest and court costs.

Dragon is represented by J. Douglas Sunseri, Svetlana "Lana" Crouch, and Edward C. Vocke IV. of Nicaud & Sunseri in Metairie.

U.S. District Judge Carl J. Barbier is assigned to the case.

Case No. 2:12-cv-02412

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