Four months after the litigation begun, a certificate of discovery has been filed in a trip and fall lawsuit against CVS Pharmacy.

As previously reported, Ava Quimby filed suit against CVS Pharmacy on Aug. 31 in Jefferson County District Court, alleging there should have been "caution signs" around an empty pallet.

Court records show that on Nov. 15 Quimby filed a certificate of discovery that included her response to CVS' request for disclosure; answer and objection to CVS' first set of interrogatories and her response and objection to CVS' request for production.

The petition states that on Sept. 25, Quimby was shopping at the CVS on College Street in Beaumont when she tripped "on a pallet at the end of a display counter that had no merchandise on it and was protruding into the walkway."

"There were no caution signs or any warning," the suit states. "Quimby fell across the pallet landing on her legs, hand, arm and shoulder. She hit her head on the floor as she skidded across the pallet."

Quimby is suing for her alleged past and future medical expenses, mental anguish, pain, impairment, disfigurement and lost wages, plus all court costs.

Attorney Jane Leger of the Beaumont law firm Provost Umphrey represents her.

Judge Milton Shuffield, 136th District Court, is assigned to the case.

Case No. D190-764

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