dangerously defective Ninja blenders regardless of the risk of significant injuries to Plaintiff and
consumers like her.
4. Defendant ignored its knowledge of these defects in its Ninja blenders in order to
continue generating a profit from the sale of said Ninja blenders, demonstrating a callous, reckless,
willful, depraved indifference to the health, safety and welfare of Plaintiff and consumers like her.
5. As a direct and proximate result of Defendant’s conduct, the Plaintiff in this case
incurred significant and painful bodily injuries, medical expenses, physical pain, mental anguish,
and diminished enjoyment of life.
PLAINTIFF ANGELA CAPPELLETTI
6. Plaintiff is a resident and citizen of the city of Central Islip, County of Suffolk,
State of New York.
7. On or about March 26, 2020, Plaintiff suffered serious and substantial lacerations
as the direct and proximate result of the Ninja blender’s blade detaching from blade base during
the normal, intended use of the Ninja blender. The incident occurred as the result of the Ninja
blenders’ defect(s), namely, the Ninja blender’s use of an unsecured blade assembly.
DEFENDANT SHARKNINJA OPERATING, LLC
8. Defendant SharkNinja designs, manufacturers, markets, imports, distributes and
sells a variety of consumer products, including the subject Ninja blender. Defendant SharkNinja
is a Massachusetts Limited Liability Corporation incorporated in the State of Delaware and has a
principal place of business located at 89 A St. # 100, Needham, MA 02494. Defendant SharkNinja
has a registered service address Corporation Trust Center, 1209 Orange Street, Wilmington, DE
19801.
Case 2:23-cv-02144 Document 1 Filed 03/20/23 Page 2 of 11 PageID #: 2
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