In a recent lawsuit, captioned Stagner v. Trader Joe’s, Index # 161608/2015 (N.Y. Sup. Ct. filed Nov. 11, 2015), plaintiff Diana Clair Stagner (and her husband Jerry Lanning) allege that she was injured when, while at the checkout counter with goods at an Upper West Side Trader Joe’s, “[an employee or agent of] Defendant Earlybird [Delivery Systems LLC] crashed into [her] with a six foot high wheeled cart … completely filled with groceries, causing her to suddenly be thrown to the ground, and momentarily lose consciousness.” Her complaint seeks $1.1 million in damages (even though CPLR 3017(c) prohibits such allegations).