mo4 project a complete complaint

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School

Ivy Tech Community College, Indianapolis *

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Course

103

Subject

Law

Date

Jan 9, 2024

Type

docx

Pages

4

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Madison Groves LEGS103 MO4: Project A Complete Complaint Caption STATE OF INDIANA)IN THE CIRCUIT COURT OF MONROE COUNTY SS: COUNTY OFMONROE Irene M. Injured Plaintif v. Samuel S. Speedman and Polly P. Passenger Defendants COMPLAINT TO RECOVER DAMAGES FOR PERSONAL INJURIES Irene Injured (“Injured”), plaintif herein, by counsel, in support of her Complaint to Recover Damages for Personal Injuries(this “Complaint”) respectfully states to the Courts as follows: Parties 1. Injured is a female resident of the state of Indiana. 2. Samuel Speedman, defendant herein, is an adult male resident of the state of Indiana 3. Speedman is amendable to service at 222 Defendant Drive, Bloomington, IN 46555 Jurisdiction and Venue 4. This Court is a general jurisdiction and therefore authorized to hear the matters of the type set forth in the Complaint. 5. Venue is proper in this matter pursuant to Ind.T.R. 75(A)(3) and (8) Verification I, Irene Injured, affirm, under the penalties for perjury, that the foregoing representation are true, 1
Madison Groves LEGS103 MO4: Project A Complete Complaint __________________ Irene Injured, Plaintif Request for Relief Wherefore, Irene Injured, plaintif herein by counsel, respectfully requests that the Court award her damages for the injuries she sustained and for all other just and proper relief in the premises. Respectfully Submitted, Irene Injured, Plaintif __________________ Luann L. Lawyer Luann L. Lawyer Lawyer & Ivy, P.C. 50 W Procedure Place, Suite 509 Indianapolis, IN 26255 Facts 1. Irene Injured was in a car accident on Arlington Avenue near Broadway Boulevard in Marion County, Indiana. 2. It was at 7:50AM on January 21of last year. 3. Irene drove a 2020 Chevrolet Cavalier with burned out taillights. 4. The brake lights were working in the vehicle. 5. Injured sustained severe damage to her right hand and arm. 6. Her medical treatment is ongoing. 7. Samuel Speedman was late for work on the morning of January 21 of last year. 8. His windows were still frosted over from being parked outside overnight. 2
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