PHILADELPHIA – A new lawsuit says that negligence on the part of a Philadelphia pizza parlor resulted in a fall and serious knee and spine injuries for one of its plaintiffs.

Karen Mosczczynski and Thomas Mosczczynski of Philadelphia filed suit in the Philadelphia County Court of Common Pleas on May 2 versus Ernie’s Pizza, Inc. (trading as “FPJ Enterprises, Inc.” and doing business as “Ernie’s Pizza”), also of Philadelphia.

“On or about May 3, 2016, it was raining when the plaintiff, Karen Mosczczynski, a business invitee, entered the pizza shop and tripped, slipped, stumbled and/or fell over a rug and/or floor mat negligently and improperly placed and not secured to the floor inside the entrance of the premises, which had become folded over, bunched up or otherwise was in a manner as to cause a tripping and slipping hazard to those lawfully entering the premises,” the lawsuit reads.

Per the litigation, the defendants were responsible for “failing to place the floor mat/rug securely, or failing to secure said floor mat/rug in a proper manner, and/or placing an improper type of floor mat rug in the premises for the purpose intended, and “failing to properly and adequately glue, connect, and/or secure the floor mat and/or rug to the floor,” among other violations.

In the process, Karen suffered lumbosacral disc herniation(s) and sprain/strain; cervical strain/sprain and aggravation of cervical spondylosis; cervical and lumbar radiculopathies and/or radiculitis; post-traumatic bursitis of both knees, sprain and strain of the knees, possible meniscal injuries of the knees and muscle spasms and exacerbation of pre-existing conditions. Thomas also sues for loss of consortium, in relation to his wife’s injuries.

For counts of negligence and loss of consortium, the plaintiffs are each seeking damages, jointly and severally, in excess of $50,000, plus punitive damages, interest, costs and delay damages in this matter.

The plaintiff is represented by Rania Major in Philadelphia.

Philadelphia County Court of Common Pleas case 180404989

From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at

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