“Wells Fargo Staff admitted to the plaintiff that Wells Fargo staff needed to hire an exterminator to spray on a regular basis the chairs in the lobby. In addition, Wells Fargo staff also admitted to the plaintiff and that they only clean the chairs for Wells Fargo staff inside the cubicles.”

💡 Wells Fargo employees explicitly admitted they maintained employee furniture while neglecting customer areas, proving the company knowingly prioritized staff over customer safety.

“The entire office staff employed by Wells Fargo that day saw plaintiff’s leg and agreed that it was red freshly bit. The whole staff confirmed the presence of bedbugs.”

💡 All bank employees witnessed and confirmed King’s injuries and the bedbug infestation, eliminating any possibility Wells Fargo could claim ignorance of the dangerous condition.

“She began to panic and ran behind the bank teller counter. She gave plaintiff her business card and informed plaintiff that she would contact him the next day.”

💡 The bank teller’s frightened response to seeing King’s bites demonstrates the obvious severity of his injuries and the shocking nature of the infestation.

“Despite medication and medical intervention, plaintiff’s itching and welting continued approximately two (2) weeks, resulting in severe skin irritations and abrasions to the point of bleeding.”

💡 King suffered for two full weeks despite medical care, proving this was not a minor inconvenience but a serious injury requiring extended treatment and causing lasting harm.

“The next day, Wells Fargo hired an exterminator to spray the premises.”

💡 Wells Fargo called pest control only after King was injured, proving the company took a reactive cost-saving approach rather than preventing foreseeable harm through routine maintenance.

“At all times pertinent, defendant owed plaintiff a duty under §§ 509.211(6)-(7), Fla. Stat., to keep their furniture at the premises disinfected and to refrain from providing furniture that was infested with bedbugs, the breach of which constitutes negligence per se.”

💡 Florida law explicitly requires businesses to keep furniture disinfected and free from bedbugs, making Wells Fargo’s violation a clear-cut breach of statutory duty.

“At all times pertinent, defendant was in exclusive possession and control of the Wells Fargo, and defendant knew or should have known about the bedbug infestation.”

💡 Wells Fargo controlled the premises and had both knowledge and responsibility for the dangerous condition but failed to act, establishing clear liability.

“At all times pertinent, defendant negligently and recklessly failed to maintain their premises to be free of bedbug infestation.”

💡 The complaint characterizes Wells Fargo’s conduct as both negligent and reckless, suggesting the company consciously disregarded known risks to customer safety.

“Plaintiff suffered temporary and permanent bodily injuries, endured pain and suffering and will continue to do so in the future, has incurred medical expenses, and will continue to do so in the future, has incurred lost wages in an undetermined amount, loss of consortium, and loss of plaintiff’s good health.”

💡 King’s injuries are permanent, meaning Wells Fargo’s cost-cutting decision created lasting harm that will affect him for the rest of his life.

“Pursuant to the agreement, defendant expressly agreed to provide the plaintiff with a safe and visitable bank. Separate and apart from defendant’s failure to perform their obligations under the agreement, defendant without good faith breached the implied covenant of good faith and fair dealing by: (1) failing to maintain the premises in a reasonably safe and visitable condition; (2) failing to warn plaintiff of the bedbug infestation; (3) advertising its property as a reputable and established banking facility, thereby inducing plaintiff to enter the agreement; and (4) failing to eliminate the bedbug infestation despite defendant’s knowledge of the same.”

💡 Wells Fargo advertised itself as reputable to attract customers while simultaneously concealing dangerous conditions, demonstrating bad faith and deceptive business practices.

“During plaintiff’s visit, after sitting down on defendant’s furniture available for customers at the lobby, plaintiff began suffering extreme itching and welting on plaintiff’s body.”

💡 King’s symptoms began immediately upon contact with the furniture, establishing direct causation between Wells Fargo’s negligence and his injuries.

“While over-the-counter salves and medication did not remedy the itching and welting, plaintiff sought medical treatment and was diagnosed with insect bites: to wit, bedbugs.”

💡 A medical professional confirmed the bedbug diagnosis, providing expert verification that Wells Fargo’s infested furniture directly caused King’s injuries.

“At all times pertinent defendant had a duty to inspect its premises and to make the premises safe and free from unreasonably dangerous conditions, including bedbug infestation.”

💡 Wells Fargo had both a legal and ethical duty to inspect for and eliminate health hazards, but the company failed this basic obligation to customers.

“Defendant, through their agents or employees, created an unreasonably unsafe condition at the premises, at all times pertinent.”

💡 The complaint establishes that Wells Fargo employees created the unsafe condition through their actions or inactions, making the company directly responsible.

“Plaintiff fully performed plaintiff’s duties under the agreement by paying for the banking services.”

💡 King fulfilled his end of the bargain by paying for services, but Wells Fargo failed to provide the safe environment it promised, creating a one-sided exploitation.