1. THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF KANSAS
Grace Crashenburn )
)
Plaintiff, )
) Case No. _______
v. ) Court No. ______
)
Buy-Mor, Inc., )
Defendant. )
COMPLAINT
COMES NOW the Plaintiff, Grace Crashenburn, by and through her attorney, Dolly
Dooright, and for her cause of action against Defendant, Buy-Mor, Inc., respectfully states as
follows:
Jurisdictional Statement
1. This suit is brought pursuant to 28 U.S.C. §1332; jurisdiction of this Court is
based on diversity of citizenship.
2. Plaintiff, Grace Crashenburn, is an individual residing at 5018 W. 96th
Terrace, Overland Park, Johnson County, Kansas.
3. Defendant, Buy-Mor, Inc., is a company whose corporate headquarters is
located at 13579 Holmes, Suite 105, Kansas City, Jackson County, Missouri.
4. The amount in controversy exceeds, exclusive of interest and costs, the sum of
seventy-five thousand dollars.
5. Plaintiff is domiciled in Overland Park, KS, and the Defendant is a corporation
incorporated under the laws of MO, and the amount in controversy exceeds $75,000; therefore,
this Court has jurisdiction of this matter pursuant to the provisions of 28 U.S.C. §1332.

2. 2
Claim for Negligence
6. This suit is brought for the recovery of damages to which Plaintiff is legally
entitled as the result of a shopping cart incident which occurred on October 23, 2014, at
the company location of 12345 College Boulevard in Overland Park, Johnson County,
Kansas.
7. At that time, Defendant was open to the public, and therefore had a duty to
maintain the safety of the premises and line the shopping carts up carefully.
8. Defendant failed to exercise that degree of care in the operation of its equipment
as would have been exercised by a reasonable and prudent company under the same or similar
circumstances; therefore, Defendant’s conduct constituted negligence.
9. As a result of Defendant’s negligence, Defendant’s carts violently struck the
Plaintiff at that time causing the Plaintiff to fall and causing the soda stand to fall on her head,
thus causing massive injuries to Plaintiff.
10. Plaintiff has incurred, and will continue to incur, charges for hospitalization,
physical therapy, and other medical services, and has lost time from work and was prevented
from completing her job to her fullest ability.
11. Furthermore, plaintiff has suffered, and will continue to suffer, great physical pain
and lost enjoyment. Plaintiff’s damages resulting from these injuries are in excess of seventy-five
thousand dollars ($75,000.00).
12. But for Defendant’s negligent and reckless conduct, Plaintiff would not have
suffered these injuries and losses; therefore, Defendant’s negligence was a direct and proximate
cause of Plaintiff’s injuries and damages.

3. 3
Prayer for Relief
WHEREFORE, Plaintiff respectfully prays this Court for judgment as follows:
First, that the Court enter judgment against the Defendant for a sum in excess of seventy
five thousand dollars ($75,000.00), and
Second, that Plaintiff be allowed to recover from Defendant her attorney’s fees, any costs
of this action, and such other relief as the Court deems just and equitable.
Respectfully submitted,
NOBLE & JUSTUS, P.C.
ATTORNEYS FOR PLAINTIFF
By: Dolly Dooright
Kansas Bar No. 29097
Noble & Justus, P.C. 9616
Indian Creek Pkwy,
Suite 900
Overland Park,Kansas 66212
(913) 469-6800
ATTORNEY FOR PLAINTIFF

4. THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF KANSAS
Grace Crashenburn )
)
Plaintiff, )
) Case No. ______
v. ) Court No. ______
)
Buy-Mor, Inc., )
Defendant. )
PLAINTIFF’S DEMAND FOR JURY TRIAL
COMES NOW Plaintiff, by and through her attorney, and demands trial by jury onall
issues so triable.
Respectfully submitted,
NOBLE & JUSTUS, P.C.
ATTORNEYS FOR PLAINTIFF
By: Dolly Dooright
Kansas Bar No.
29097
Noble & Justus, P.C.
9616 Indian Creek
Pkwy,
Suite 900
Overland Park,Kansas 66212
(913) 469-6800
ATTORNEY FOR PLAINTIFF