IN THE CIRCUIT COURT FOR DAVIDSON COUNTY, TENNESSEE

LAKEYA STARNES, individually)

and on behalf of her minor )
daughter, ARIYANA STARNES, )
)
Plaintiffs, )
) CASE NO. 16C-_______
v. )
) Jury Demand (12)
METROPOLITAN GOVERNMENT OF )
NASHVILLE AND DAVIDSON )
COUNTY,TENNESSEE, )
METROPOLITAN BOARD OF )
EDUCATION, and METROPOLITAN )
NASHVILLE PUBLIC SCHOOLS, )
)
Defendants. )

COMPLAINT

The Plaintiffs, Lakeya Starnes, individually and on behalf of her daughter, Ariyana

Starnes, state for this cause of action as follows:

The Parties

1. The Plaintiffs, Lakeya Starnes and her minor daughter, Ariyana Starnes,

are citizens and residents of Davidson County, Tennessee.

2. The Defendants operate the public school system in Nashville, Davidson

County, Tennessee. The Defendants are responsible for the operation of the school

buses for the public schools in Nashville.

3. The school bus accident described herein occurred in Davidson County,

Tennessee on September 2, 2015.

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Preliminary Issues

4. This is a negligence action involving a September 2, 2015 school bus

accident that involved the Plaintiff, Ariyana Starnes. This accident occurred in

Davidson County, Tennessee.

5. This lawsuit was filed within the applicable statute of limitations.

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6. Venue and jurisdiction are appropriate with this Court.

Cummings Manookian 45 Music Square West, Nashville, Tennessee 37203

7. The Defendants were properly served with this lawsuit and the Complaint

via service upon the Metropolitan Government of Nashville, Department of Law, John

Cooper Director of Law, Metropolitan Courthouse #108, Nashville, TN, 37219.

8. Tennessee law applies to this matter.

Facts and claims

9. On September 2, 2015, the Plaintiff, Ariyana Starnes, was a passenger on

a public school bus when it was hit by another school bus in a parking lot. This

collision between the buses caused the Plaintiff, Ariyana Starnes, to hit her head and

she received a concussion as a result. The accident occurred as a result of the

Defendants employee or agent negligently driving the school bus that the Plaintiff,

Ariyana Starnes was on, and/or as a result of the Defendants employee or agent

negligent driving the school bus that collided with the school bus on which the Plaintiff,

Ariyana Starnes, was a passenger. The Defendants employees or agents

negligence caused the accident, which resulted in physical injuries and medical

expenses.

10. The Plaintiff, Ariyana Starnes, did nothing to negligently cause the accident.

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11. The accident occurred as a result of the negligence of the Defendants

employee or agent, including, but not limited to, not keeping a careful watch, and not

driving carefully.

12. As a matter of law, the Defendants employee or agent violated Tenn. Code

Ann. section 55-8-136(b) by failing to operate a motor vehicle with due care, by not
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keeping a safe lookout, and by not devoting full time and attention to operating a
Cummings Manookian 45 Music Square West, Nashville, Tennessee 37203

motor vehicle, all of which, in part or in combination, caused the car accident. The

Defendants employees or agents violations of these statutory provisions constitute

negligence per se, to which the Defendants are liable to the Plaintiff for all resulting

injuries and damages the Plaintiff sustained, because the Plaintiff is a member of the

class of persons who these statutes exists to protect.

13. The Plaintiff, Ariyana Starnes, suffered injuries as a result of the accident,

including physical pain and suffering. These injuries included, but are not limited to,

(1) an injury to her neck, (2) an injury to her head, and (3) a concussion. The Plaintiff,

Ariyana Starnes, received health care on each of the first three days after the

September 2, 2015 accident for the headaches and light sensitivity she suffered. She

was diagnosed with a Concussion. The Plaintiff, Ariyana Starnes, will have future

physical pain and suffering as a result of the injury, including headaches and light

sensitivity.

14. As a result of the care and treatment provided to the Plaintiff, Ariyana

Starnes, for her injuries from the accident, the Plaintiffs incurred medical expenses,

all of which were reasonable and necessary in amount, and which were caused by

the car accident. These medical bills are attached, and the documented charges are

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presumed to be necessary and reasonable pursuant to Tenn. Code Ann. section 24-

5-113. The adult Plaintiff, Lakeya Starnes, is financially responsible for the medical

bills incurred for her daughters care, including for the medical expenses incurred

related to the injuries described herein.

15. The negligence of the Defendants employee or agent caused the bus
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accident. The negligence of the Defendants employee or agent was the actual cause
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and proximate cause of the aforementioned injuries and damages to the Plaintiff. The

Defendant is liable to the Plaintiff for the Plaintiffs injuries and damages.

WHEREFORE, the Plaintiffs pray:

1. That service of process issue for the Defendants, and which counsel for the

Plaintiffs will execute.

2. That the Plaintiffs recover from the Defendant all of the following items:

A. Compensatory damages for the Plaintiffs injuries, including, past and

future physical pain and suffering, past and future emotional pain and
suffering, and medical expenses, in an amount up to $100,000.00;

B. Prejudgment interest with regard to the medical expenses, lost income,

and lost earnings;

C. Postjudgment interest at the maximum rate allowed under Tennessee

law;

D. All recoverable costs in this action; and,

E. Any other relief which the Court determines to be just and proper.

WHEREFORE, the Plaintiffs sue the Defendants for the damages outlined above,

pursuant to the terms of the facts, the claims, and Tennessee law.

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Cummings Manookian 45 Music Square West, Nashville, Tennessee 37203
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www.cmtriallawyers.com
Nashville, TN 37203

(615) 266-0250 fax

45 Music Square West

Attorney for the Plaintiff

(615) 266-3333 phone

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Respectfully submitted,

Cummings Manookian PLC

Brian Cummings, #19354

bcummings@cummingsmanookian.com
AUTO ACCIDENT LAWSUIT