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LA205 Unit 3 Chapter 4 Negligence Complaint Sandra Black or-1

LA205 Unit 3 Chapter 4 Negligence Complaint Sandra Black or-1

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Published by: LegalDoomUT on Sep 12, 2010
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09/12/2010

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Jessica White (008888)White, Wilson, & McDuff 
Federal Plaza Building, Suite 700Third and Market StreetsProvo, UT 84604Telephone (801) 344–0000Facsimile: (801) 344-1100 jessicaW@wwmd.com
 Attorney for Plaintiff 
 
IN THE FOURTH JUDICIAL DISTRICT COURT125 North 100 West, ProvoUTAH COUNTY, STATE OF UTAH
CAROLINE LITTLE andCARL LITTLEPlaintiffs,v.MARSHA PETERSON andACME SPECIALTY CAR PARTS, INC.Defendants,
COMPLAINT FOR NEGLIGENCE
Civil Case No. ______________ Judge:Commissioner:Plaintiff, Caroline Little, by and through her undersigned attorney, Jessica White,White, Wilson & McDuff, as and for its cause of action against the above-nameddefendants states and alleges:1.Plaintiff, Caroline Little, is an individual and is now, and at all times mentioned inthis complaint is resident of Utah County, Utah. The jurisdiction of this court is basedon the amount in controversy in the action, which is more than $10,000. ThePlaintiffs demand trial by jury in this matter.2.Defendant Marsha Peterson is now, and at all times mentioned in this complaint as anindividual and employee of ACME Specialty Car Parts, Inc.1
 
3. Defendant ACME Specialty Car Parts, Inc. is now, and at all times mentioned in thiscomplaint as a corporation organized and existing under the laws of the State of Utah,with its place of business in Utah County, Utah.4. Plaintiff is informed and believes, on the basis of that information and belief alleges,that at all times mentioned in this complaint, the defendant, Marsha Peterson, is theagent and employee of the codefendant, and in doing the things alleged in thiscomplaint was acting within the course and scope of that agency and employment.5.Plaintiff does not know the true names of defendants and therefore sues them by thosefictitious names. Optionally, in addition to language in charging allegations thatincludes fictitiously named defendants: Plaintiff is informed and believes the basis of that information and belief alleges that each of those defendants was in some manner negligently and proximately responsible for the events and happenings alleged in thiscomplaint and for plaintiff's injuries and damages.6.On March 23, 2010, at approximately 3:00 p.m. Plaintiff, Caroline Little, who islegally blind and uses a white cane for the blind, started to cross the street from thesoutheast corner of A Street and Oak Boulevard, Provo, Utah County, Utah, wherethere is a traffic light.7. Marsha Peterson, a delivery driver for Acme Specialty Car Parts, Inc, wassouthbound on Oak Boulevard and made a left turn to head east on A Street. TheDefendant completed her turn and struck, the Plaintiff, Caroline Little, with theDefendants’ company vehicle, which is owned by Acme Specialty Car Parts, Inc.8.Defendant Peterson operated the delivery vehicle negligently by:(a)failing to exercise proper lookout(b)failing to give the right of way to a blind pedestrian carrying a white cane(c)failing to exercise adequate control of said vehicle(d)failing to exercise due and adequate care under the circumstances and law1.As a direct result of the Defendants’ negligence, the Plaintiff was struck down by theDefendants' delivery vehicle and seriously injured.2.Because of said negligence, the Plaintiff was admitted to the hospital and kept therefor twenty-five days suffering from scrapes, bruises, a fractured right wrist, permanent nerve damage to the left leg, a concussion, some neurological damage,2
 
depression and other maladies, causing her intense pain, great suffering andconsiderable inconvenience for her life time.3.As a consequence of the Defendants’ negligence and the previously mentionedinjuries, the Plaintiff has and will incur substantial monetary losses for hospital andmedical care, domestic services, hospice services, assisted living housing and property damages to her clothing, cell phone, and a diabetes testing kit.WHEREFORE, Plaintiff demands judgment against defendants, and each of them in theamount of two million dollars ($2,000,000,000) together with punitive damages for emotional distress and pain and suffering in the amount of three million dollars($3,000,000,000) and the costs and disbursements of this action and for such other relief as the court may deem just and proper.
COUNT TWO
4.The Plaintiffs hereby allege and incorporate by reference paragraphs 1 through 11 of Count One.5.Because of the Defendants’ negligence, Plaintiff William Forrester has suffered a lossof consortium with his wife, Caroline Little, in the amount of two million dollars($2,000,000,000).Wherefore, Plaintiff Carl Little demands judgment against the Defendants in the sum of two million dollars ($2,000,000,000) and costs for such other relief as this court maydeem just and proper.DATED this 28
th
day of April 2010. ___________________________ JESSICA WHITEAttorney for Plaintiff 
VERIFICATION
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