Weil, Sue, and Howe, LLC
Gisselle Yelitza Fajardo Reyes - #11400
Attorney for Petitioner
514 Royal Street, Suite #14, door #1
Salt Lake City, UT 84060
Telephone: (801)865-5177
Email: gisselle00fajardo@gmail.com
IN THE THIRD JUDICIAL DISTRICT COURT OF SALT LAKE COUNTY
STATE OF UTAH
| Max Weber, Plaintiff, vs. Sleepy Eyes Clinic and Lary Bud, Defendant. | Case No. 123456789 Honorable Judge Ryan M. Harris |
COMPLAINT
Dear Sleepy Eyes Clinic and Lary Bud,
I am writing to you on behalf of Max Weber, a client of our law firm, Weil, Sue, and Howe, LLC, regarding a serious matter involving your product, "No Sleepy Eyes," and its associated company, Sleepy Eyes Clinic, owned by Lary Bud. Mr. Weber bought your product, "No Sleepy Eyes," from a local Salt Lake City, UT retailer as a result of your national marketing campaign endorsing the product as a means of assisting people with their morning baggy eyes. Regretfully, the medication's package did not include any warning labels.
After using the solution for three nights, Mr. Weber developed a crippling infection in both of his eyes as a result of the chemicals triggering a significant immunological response. Mr. Weber has experienced permanent loss as a result of this infection, losing 15% of his vision in his right eye and 30% in his left. According to the medical prognosis, he is now at risk of acquiring glaucoma, which could result in the total loss of vision in both eyes.Mr. Weber is facing extremely upsetting circumstances that will change his life. Due to these injuries, he not only has to deal with ongoing physical pain and irreversible eyesight impairment, but he also has to deal with a great deal of emotional suffering and difficulties in both his personal and professional life.
It is apparent that there is a major violation of customer trust and safety regulations when warning labels are missing from the packaging of your products. Furthermore, Sleepy Eyes Clinic and its owner, Lary Bud, were negligent in their inability to thoroughly examine and evaluate the possible risks connected with the "No Sleepy Eyes" product prior to its widespread availability and sale.
In view of the aforementioned, we require that Sleepy Eyes Clinic and Lary Bud adopt the following measures:
1. Reimburse Mr. Weber immediately for the pain and suffering, missed wages, and medical costs he incurred as a result of using your product.
2. Put a halt to the "No Sleepy Eyes" product's manufacturing, shipping, and retail sales until it has passed rigorous regulatory inspections and been given the go-ahead to bear warning labels informing customers of any possible health hazards.
3. Publicly apologize to Mr. Weber and other customers who have suffered because of your product's use. Acknowledge that you made mistakes in guaranteeing its security and promise to put customers' needs first in all of your future undertakings.
We anticipate hearing back from Sleepy Eyes Clinic and Lary Bud as soon as possible on the aforementioned requests. If these issues are not resolved to Mr. Weber's satisfaction, he may file a lawsuit to get full compensation for his injuries and hold your organization legally responsible for its carelessness.
DATED this 20th day of February 2024.
/s/ Gisselle Y. Fajardo Reyes