Jon Campisi Aug. 5, 2011, 7:55am

A Bala Cynwyd, Pa. woman who alleges she sustained serious injuries after tripping outside of a Center City Philadelphia building is suing the property owner in civil court.

Attorneys Thomas R. Kline and James J. Waldenberger, of the Philadelphia firm Kline & Specter, filed the premises liability claim Aug. 3 at the Philadelphia Court of Common Pleas on behalf of Virginia Miller.

The defendant named in the suit is a limited partnership called PA-1601 Market Street.

According to the complaint, Miller was walking along the outside of the defendant’s property on Aug. 25, 2009, when she “suddenly and without warning” tripped over a loose masonry paver and fell to the ground.

As a result of her fall, Miller sustained a knee injury, a concussion, traumatic brain injury, injuries to her organs and tissue, cognitive and behavioral impairment, headaches, balance problems, hand-eye coordination impairment, noise sensitivity, memory loss, depression and emotional distress, pain and suffering and other ills and injuries, the lawsuit states.

The lawsuit accuses the defendant of carelessness, negligence and recklessness for permitting the dangerous loose paver condition to exist on its premises, failing to repair the hazardous condition, improperly installing masonry pavers in the area, and failing to properly inspect and maintain the area.

In addition to her physical injuries, Miller also suffered humiliation, mental anguish, embarrassment, a loss of life’s pleasures, fear and anxiety and a loss of earning power and capacity, the suit states. The latter relates to her inability to work because of the incident.

Miller demands judgment against the defendant in a sum in excess of $50,000 in compensatory and punitive damages as well as other relief the court may deem appropriate.

The plaintiff has demanded a jury trial.

The case number is 110800748.

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