M04- Project A - Complete Complaint
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Ivy Tech Community College, Indianapolis *
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Course
103
Subject
Law
Date
Feb 20, 2024
Type
docx
Pages
5
Uploaded by AgentGull3714
Erica Stiening
LEGS 103
M04: Project A - Complete Complaint
STATE OF INDIANA
)
IN THE SUPERIOR COURT OF MARION COUNTY
) SS:
COUNTY OF MARION
)
CAUSE NO:
IRENE M. INJURED, )
)
Plaintiff,
)
)
v.
)
)
SAMUEL S. SPEEDMAN
)
and POLLY P. PASSENGER,
)
Defendants.
)
COMPLAINT TO RECOVER DAMAGES FOR PERSONAL INJURIES
Irene M. Injured (“Injured”), plaintiff herein, by counsel, in support of her
Complaint to Recover Damages for Personal Injuries
(this “Complaint”) respectfully states to
the Court as follows:
Parties
1.
Injured is an adult female resident of the state of Indiana.
2.
Samuel S. Speedman (“Speedman”), defendant herein, is an adult male resident of the state of Indiana. 3.
Speedman is amenable to service at 222 Defendant Drive Bloomington, IN 46555. 4.
Polly P. Passenger (“Passenger”), defendant herein, is an adult female resident of the state
of Indiana. 1
Erica Stiening
LEGS 103
M04: Project A - Complete Complaint
5.
Passenger is amenable to service at 333 Bystander Boulevard Lafayette, IN 46555. 6.
Speedman and Passenger are coworkers at Bank Nine and Three Quarters and carpool regularly. Jurisdiction and Venue
7.
This Court is a state court of general jurisdiction and therefore authorized to hear the matters of the type set forth in the Complaint. 8.
Venue is proper in this matter pursuant to Ind. T.R. 75(A)(3). Facts
1.
The plaintiff was in Marion County, Indiana on January 21
st
, 2023. 2.
Plaintiff was driving a 2020 Chevrolet Cavalier.
3.
The morning of January 21
st
, 2023 was frosty. 4.
The plaintiff’s taillights were burnt out. 5.
The plaintiff’s brake lights were in working condition.
6.
At approximately 7:50 am, the plaintiff was injured in a car accident on Arlington Avenue
near Broadway Boulevard. A deer ran out in front of the plaintiff’s vehicle causing her to slam on the brakes.
7.
Samuel Speedman was driving a 2018 Ford F250 pickup truck.
8.
Speedman’s windshield was still frosted with only a small area scraped clean.
9.
Speedman rear-ended the plaintiff’s vehicle when he did not see her brake lights.
10. The plaintiff’s vehicle sustained rear-end damage.
11. The plaintiff sustained severe damage to her right hand and arm. 2
Erica Stiening
LEGS 103
M04: Project A - Complete Complaint
12. The plaintiff’s medical treatment is ongoing.
13. The plaintiff was a self-employed accountant before the accident.
14. Due to the plaintiff’s injuries, she cannot use her adding machine or computer.
15. Speedman’s vehicle sustained front-end damage as a result of hitting the plaintiff’s vehicle. 16. Polly Passenger was a passenger in Speedman’s vehicle at the time of the accident. 17. Speedman and Passenger are co-workers at Bank Nine and Three Quarters.
18. Speedman is also employed at IndyEatz.
Count 1: Negligence
19. The defendant had the duty to follow safety protocols before operating a vehicle.
20. The defendant had the duty of care via maintenance and ownership of a vehicle. 21. The defendant had the duty to use the utmost care and concern while operating a vehicle. 22. The defendant breached his duty by not clearing his windshield completely and limiting his view. 23. The defendant breached his duty by rear-ending the plaintiff.
24. The plaintiff sustained injuries to her right arm and hand, and it is unknown if she will regain full function of her right arm.
25. The plaintiff has been unable to work due to her injuries.
26. The plaintiff’s vehicle was damaged.
27. The plaintiff’s medical treatment is ongoing.
28. But for the defendant’s negligence, the plaintiff would not have been injured. 3
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