1. At all relevant times, Plaintiff Donna Garber regularly purchased and consumed Defendant’s carrots from Kroger’s in Harrisburg, Virginia, and Walmart in Luray, Virginia.
  2. On or about November 12, 2024, Plaintiff began experiencing symptoms of illness, including abdominal cramps and diarrhea, which quickly progressed to bloody diarrhea. Plaintiff also developed malaise and lack of appetite.
  3. When her symptoms persisted and worsened, Plaintiff sought medical attention on November 14, 2024, at the Page Memorial Hospital Emergency Room.
  4. At the Emergency Room, Plaintiff underwent blood tests and a CT scan. The CT scan revealed acute colitis, and Plaintiff was subsequently admitted to the hospital for treatment.
  5. During her hospitalization, Plaintiff provided a stool sample, which was later confirmed to be positive for Escherichia coli O121. 
  6. Plaintiff remained at the hospital until November 17, 2024.
  7. Plaintiff continues to suffer from weakness, fatigue, loss of appetite, and persistent stomach cramping.
  8. As a direct result of being sickened by Defendant’s defective food product, Plaintiff has incurred, and will continue to incur, substantial medical bills and expenses associated with the treatment of her injuries; has suffered, and will continue to suffer, lost wages and wage-earning capacity; and has suffered, and will continue to suffer, significant pain, emotional anguish, and other damages.

https://www.marlerblog.com/files/2024/11/Garber-Carrots-Complaint-11.20.24.pdf