IN THE CIRCUIT COURT OF MARYLAND FOR BALTIMORE COUNTY

Neil Caffery *

Plaintiff *

v. *

Ted Lewis *

Defendant *
CASE NO. 123456
*

*
* * * * * * * * * * * * * *

COMPLAINT FOR NEGLIGENCE

Plaintiff Neil Caffery, (Plaintiff), through its undersigned attorney, brings this

Complaint for negligence, and in support states:

Jurisdiction and Venue

1. This Court has personal jurisdiction over Defendant Ted Lewis, pursuant to Md.

Cts. & Jud. Proc. Code Ann. 6-102 as Defendant conducts business in Maryland and is a

resident of Maryland.

2. Venue is proper in Baltimore County pursuant to Md. Cts. & Jud. Proc. Code

Ann. 6-201(a), as Defendant resides in Baltimore County, Maryland.

Parties
3. Plaintiff is Neil Caffery who is residing at Defendant is Ted Lewis who is a natural

person residing at 2853 Oakridge Way 21236, Baltimore Maryland.

4. Defendant is Ted Lewis who is a natural person residing at 404 Waterlake Drive 21128,

Baltimore Maryland.

Facts

5. On January 2, 2008, at approximately 8:00 a.m., the Defendant, Ted Lewis, was
operating a vehicle, a 2004 Nissan Pathfinder, directly behind the plaintiff traveling on
Ivy Lane in Baltimore County, Maryland. The Defendant negligently operated,
maintained, and controlled said automobile by failing to come to a stop behind the
plaintiff so as to cause his vehicle to collide into the back of the vehicle being operated
by the Plaintiff, Neil Caffery.
On the occasion in question the Defendant, Ted Lewis, was negligent in the following
particulars, among others, to-wit:

a. Failure to keep vehicle under control;

a. Failure to give full time and attention;

b. Failure to keep a proper lookout;
c. Failure to reduce speed to avoid collision;
d. Unreasonable operation of a vehicle under conditions existing;
e. Failure to obey traffic control devices;
f. Negligent driving;
g. Reckless driving;
h. Failure to yield right of way.

The collision hereinabove stated was due to the sole negligence of the Defendant, Ted
Lewis, without any contributory negligence whatsoever by the Plaintiff, Neil Caffery.
 Count One
Negligence

6. The allegations of paragraphs 1 through 5 are incorporated herein by reference.

7. The Plaintiff, Neil Caffery, adopts and incorporates all of the facts and allegations set
forth above as if fully set forth herein. As a direct and proximate result of the aforesaid
collision, which was caused by the negligence of the Defendant, Ted Lewis, the Plaintiff,
Neil Caffery, who was operating the vehicle at the time of the aforesaid collision, was
suddenly thrown against the inside of the automobile, thereby causing the Plaintiff, Neil
Caffery, to suffer severe pain and permanent injury, including but not limited to, his head,
neck, both arms, shoulders, right foot, knee, low back, thighs, and buttocks, all of which
have caused him great pain and mental anguish. As a further direct and proximate result
of the negligence of the Defendant, Ted Lewis, the Plaintiff, Neil Caffery, has been
forced to expend large sums of money for hospitalization, x-rays, nurses, medical
treatment and for medicine for the treatment of the aforesaid injuries to himself. As a
further direct and proximate result of the negligence of the Defendant, Ted Lewis, the
Plaintiff, Neil Caffery, was forced to lose time from his employment and has suffered a
loss of wages for which he seeks remuneration.

WHEREFORE Plaintiff demands judgment against the Defendant in the amount of

Three Hundred Thousand Dollars ($300.000) in compensatory damages, plus costs, and post-

judgment interest, along with any other relief that the Court may find is just and equitable.

Respectfully Submitted:

Patricia Bienkowski
_____________________________________
Dale & Chip, P.A.
7200 Sollers Point Road
Essex, Maryland 22222
(p) 410-555-1212
(e) dchip@DaleandChip.com

Attorney for Plaintiff