BELLEVILLE — A woman claims she was injured when she stepped onto a damaged curb.

Paula Daley filed a complaint on Nov. 23 in St. Clair County Circuit Court against Howland 3 Investments LLC and Tracy L. Bardin, alleging they negligently permitted a curb on their premises to become dangerous.

According to the complaint, the plaintiff alleges that on Nov. 24, 2014, she was lawfully on the defendantss premises, walking in the designated parking lot, when she tripped and fell after stepping onto a damaged curb.

She claims she sustained severe injuries resulting in pain and suffering, disability, lost wages and medical expenses.

Daley alleges the defendants failed to inspect and maintain the premises in a reasonably safe condition, failed to provide a safe place to walk and failed to warn their guests of the unsafe and defective condition.

The plaintiff requests a trial by jury and seeks judgment against each defendant in excess of $50,000, plus costs of suit.

She is represented by Lloyd M. Cueto and Michael Gras of Law Office of Lloyd M. Cueto PC in Belleville.

St. Clair County Circuit Court case number 16-L-628

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St. Clair County Circuit Court
10 Public Square
Belleville, IL - 62220-1623

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