Plaintiff Complains And For Causes Of Action Alleges

Background: Based on the given complaint, on the 28th of March in 2014 the Plaintiff, Linda D. Daugherty suffered an injury on the property of Rauleigh J. Ringer at 814 N. Liberty Street, Alexandria, IN. She is claiming her injury was a result of negligence spawning from the actions, or lack thereof, by Mr. Ringer and Casual Lifestyles Realty, Inc., in which the connection of these three parties has not been clarified with certainty within the claim. The Defendants, by counsel, Mark Maynard, and, pursuant to Rule 12(E) of the Indiana Rules of Trial Procedure, moved for a more definite statement of the Plaintiff’s Complaint. Mark Maynard argues if said Plaintiff could amend her complaint that is supposedly so vague and ambiguous, the newfound clarity would help the defense frame a response to said Plaintiff’s claim. No other information could be

(1) Whether a plaintiff must plead and prove willful and wanton conduct in order to

3.  Plaintiff is ignorant of the true names and capacities of defendants sued in this complaint as DOES 1 through 10, inclusive, and therefore sues these defendants by such fictitious

For a plaintiff to win a case they need the following. Show that they are

Plaintiff, Steven Oliva, alleges as follows on knowledge as to himself and his known acts, and is informed and believes and thereby complains and alleges as follows:

Good evening Your Honor, ladies and gentlemen of the jury, and opposing counsel. Tonight you heard the testimony and evidence in Roughed Grouse High School's attempt to hide, justify, and deny their negligent actions. In order to prove Roughed Grouse High School's negligence resulting in the death of Jordan Simon, I, along with my co-counsel, had to prove our case, not beyond a reasonable doubt, but simply by a preponderance of evidence. In other words, if you were to put the evidence favoring the case of the plaintiff and evidence favorable to the defendant on a scale, we the plaintiff would have to make the scales tip ever so slightly in our favor. Ladies and gentlemen of the jury, we have done just that. We have proved to you tonight

Ms. Chaker to separately create duplicative sets of discovery to each of the Defendants is unnecessary here. Given their trustee-beneficiary relationship, defendants are of an aligned interest in this matter. Ms. Chaker seeks to assert her rights against both Ms. Lindstrom and Ms. Lindstrom-Blech under the same claims, and would provide identical discovery to each defendant even if they were served separately. Thus, even if Ms. Chaker separately served Defendants with discovery defining “you” and “your” for each individual, but otherwise identical, Defendants would provide the same responses as already furnished, and would most likely answer provide answers applicable to Defendants collectively.

When the Plaintiff resisted, Bailey physically and verbally abused her. Bailey threw her against the wall, slapped her, kicked her, punched holes in the living room walls, tore a hallway door off, and broke a bedroom window. Hearing the Plaintiff’s screaming, one of the neighbors called the police and another neighbor called Dan Houston, who never responded to the incident. The altercation stopped when the police arrived after fifteen minutes. But, Bailey’s vicious attack caused severe physical injuries to the Plaintiff including three broken ribs, and numerous cuts and bruises. She also suffered economic damages because the Defendant required her to fix the damages Bailey caused to the basic facilities (door, window, and walls) spending $2,500.

f) The trial judge referred to “large quantities of blood” around the house, when only minimal amounts were found.

The Christophers were hired by an undisclosed 3rd party to take pictures of the Du Pont facility. Workers notice an airplane circling above the plant and an investigation is launched immediately. It is determined that the Christophers are the ones in the plane and contact is made between both plaintiff and defendant. The Christophers are asked to disclose the name of the person or corporation by Du Pont and refuse.

Attempts were made to serve the Defendant JUAN ESPARZA via personal service. Affidavits of due Diligence attached hereto as exhibit “A”.

The cash collections reported by the Defendant for the period February through April of 2012 showed zero cash collections, with Three Hundred, Fifty-Eight Dollars ($358.00) in cash collections reported for May of 2012. Plaintiff did not make inquiry of the Defendant as to whether Defendant was reporting income derived from his provision of medical services in Beckley, and Defendant did not expressly inform Plaintiff that he was not reporting such income as “Cash Collections.”

12. The Defendants’ showed bad faith, breaking the said agreement and wanting the Plaintiff to lift heavy Household items with unreasonable safety conditions, unsafe environment, and gross negligence and not providing reasonable and adequate equipment and people for the said move. Especially for someone that is already disabled under federal and state laws, grossly injuring, exploiting and tricking the already Disabled Plaintiff and knowingly disregarding all reasonable safety practices

When I first read this assignment, I was very excited to go to court as I have always wanted to be a lawyer and find law and courtrooms fascinating. This experience lived up to expectations as it was very interesting and the case I witnessed was very relatable. I regularly go to a nail salon back at home and this trial will definitely make me think twice before I go back. My grandma also suffers from dementia, so I relate to the plaintiff and her experiences. However, as much as I sympathize with the plaintiff, I do not believe there is any way to prove that her infection was a direct result from the nail salon since she did not voice her concerns until three weeks later.

The plaintiff’s allegations must be stated in numerical paragraphs and each paragraph is to be limited to a single set of circumstances.