Johnson V Reedy Creek
Johnson V Reedy Creek
Johnson V Reedy Creek
CASE NO.:
MICHAEL JOHNSON,
Plaintiff,
VS.
Defendant.
/
COMPLAINT
Plaintiff, MICHAEL JOHNSON, by and through undersigned counsel, files this lawsuit against the
1. This is an action for damages in excess of $50,000.00, exclusive of costs, interest and
attorneysfees.
DISTRICT, was the owner and in possession of a certain business known as Disney Springs Orange Parking
Garage located at 1486 Buena Vista Drive, Orlando, Orange County, Florida, with said business being that of
a parking garage, open to the general public, including the Plaintiff herein.
5. On or about July 7, 2022, Plaintiff, MICHAEL JOHNSON, was a business invitee at the
Disney Springs Orange parking garage located at 1486 Buena Vista Drive, Orlando, Orange County, Florida.
On that date, Plaintiff, MICHAEL JOHNSON, was utilizing the elevator located in the above-referenced
address when it malfunctioned by dropping several feet suddenly and without warning, then stopping abruptly,
forcefully shaking, and dropping again before ascending to the fifth floor of the parking garage. As a result,
6. At all times material hereto, Defendant, REEDY CREEK IMPROVEMENT DISTRICT, had
possession and control of the parking garage known as Disney Springs Orange parking garage located at 1486
Buena Vista Drive, Orlando, Orange County, Florida and was responsible for the maintenance, upkeep and
7. At all times material hereto, Defendant, REEDY CREEK IMPROVEMENT DISTRICT, had
a. Failing to exercise reasonable care that would result in the discovery of the faulty
b. Failing to realize the faulty condition involved an unreasonable risk of harm to invitees;
c. Failing to expect that invitees would not discover or realize the danger of the faulty
d. Failing to exercise reasonable care to protect invitees against the danger of the faulty
elevator;
e. Failing to correct or adequately correct the unreasonably dangerous condition of the faulty
elevator when the condition was either known to the Defendant, had existed for a
sufficient length of time, and/or occurred with such regularity that Defendant should have
f. Failing to reasonably inspect the elevator and safely operate and maintain the elevator
DISTRICT's negligence, Plaintiff MICHAEL JOHNSON suffered bodily injury in and about his 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, loss of earnings, and loss of the ability to earn money in the future. As a result of said
10. The Plaintiff has complied with all conditions precedent to bringing this action. The Plaintiff,
through counsel and pursuant to Fla. Stat. 768.28(6), provided notice to Department of Financial Services and
Reedy Creek Improvement District of his intent to pursue this action on January 18, 2023.1
of interest and costs, and demands a trial by jury of all issues triable as of right by a jury.
1
See Exhibit A: Claimant, Michael Johnson's Notice of Potential Litigation Against Reedy Creek Improvement
District Pursuant to Florida Statute 768.28 dated January 18, 2023.
EXHIBIT A
IN RE: PRESUIT NOTICE OF CLAIM
PURSUANT TO FLORIDA STATUTE 768.28(6)(A)
MICHAEL JOHNSON,
CLAIMANT,
V.
PROSPECTIVE DEFENDANT.
And
Pursuant to Florida Statute Section 768.28, this letter will serve to notify you or otherwise
place you on notice that Claimant, Michael Johnson, has placed you on notice of their intent to
initiate litigation against a governmental entity, namely, the Reedy Creek Improvement District.
Date of Birth:
Allegations: On July 16, 2022 Michael Johnson was lawfully on the premises
owned and/or leased by Reedy Creek Improvement District at the parking garage adjacent
to Disney Springs, at Walt Disney World, in Orange County, Florida. While leaving Disney
Springs with his daughter, Michael Johnson entered Reedy Creek Improvement District's
parking garage elevator to return to his vehicle. While ascending, the elevator, without
warning, stopped abruptly, fell several feet and stopped short again between floors,
slamming the Plaintiff's body downward, and, as a consequence Michael Johnson sustained
severe bodily injury.