Module #3 Assignment - The Complaint
docx
keyboard_arrow_up
School
Ivy Tech Community College, Indianapolis *
*We aren’t endorsed by this school
Course
202
Subject
Law
Date
Feb 20, 2024
Type
docx
Pages
3
Uploaded by cesiaeves
STATE OF INDIANA
)
IN THE LITIGATION COUNTY SUPERIOR COURT NO. 5
) SS:
COUNTY OF LITIGATION
)
CAUSE NO.: 64D05-1602-CT-000086
)
)
ANN FORRESTER and
)
WILLIAM FORRESTER,
)
PlaintiffS,
)
)
v.
)
)
RICHARD HART and
)
MERCURY PARCEL
)
SERVICE, INC.,
)
Defendants,
)
COMPLAINT FOR DAMAGES
COUNT I: NEGLIGENCE
Comes now the plaintiffs, Ann Forrester and William Forrester, by counsel, Cesia Eves, Ivy
Injury Law, Inc., and for cause of action against the defendants, Richard Hart and Mercury
Parcel Service, Inc., alleges and says:
1.
On February 26, 2016, the defendant, Richard Hart, negligently operated a vehicle owned
by the defendant, Mercury Parcel Service, Inc., causing said vehicle to strike the plaintiff,
Ann Forrester, resulting in her severe injuries.
2.
The collision occurred on Highway 328 in Litigation County, Indiana.
3.
As a direct result of the defendant's negligence, Ann Forrester suffered permanent injuries, including but not limited to, extensive head trauma and multiple fractures to her legs, causing immense pain, suffering, and ongoing medical treatment.
4.
The plaintiffs have incurred significant medical expenses, loss of income, and other related expenses as a result of the defendant's negligence.
WHEREFORE, the plaintiffs respectfully prays for an award against the Defendants in an
amount that will fairly and fully compensate the Plaintiffs for all losses, injuries, and damages, for costs of this action, and for all other just and proper relief in the premises.
COUNT II: LOSS OF CONSORTIUM
Comes now the plaintiff, William Forrester, by counsel, Cesia Eves, Ivy Injury Law, Inc., and for
cause of action against the defendants, Richard Hart and Mercury Parcel Service, Inc., alleges
and says:
1.
The plaintiff, William Forrester, has suffered a loss of consortium as a result of the injuries sustained by his wife, Ann Forrester, due to the negligent actions of the defendants, Richard Hart and Mercury Parcel Service, Inc.
2.
The loss of consortium includes the loss of companionship, love, affection, society, support, and services of his wife, Ann Forrester.
3.
The plaintiff has incurred emotional distress and other damages due to the loss of consortium.
WHEREFORE, the plaintiff respectfully prays for an award against the Defendants in an amount that will fairly and fully compensate the Plaintiff for for loss of consortium, emotional distress, and all other damages recoverable under Indiana law, as well as court costs and for all other just and proper relief in the premises.
IVY INJURY LAW, INC.
BY: /s/
__
Cesia G. Eves
________
Cesia G. Eves, #12345-67
Ivy Injury Law, Inc.
1555 West 2nd Street
Indianapolis, IN 46123
Phone: 317-123-4567
Fax: 317-123-4568
REQUEST FOR TRIAL BY JURY
Comes now the plaintiffs, by counsel, Ivy Injury Law, Inc., and request that this matter be tried by jury pursuant to Indiana Trial Rule 38.
IVY INJURY LAW, INC.
BY: /s/
__
Cesia G. Eves
________
Cesia G. Eves, #12345-67
Ivy Injury Law, Inc.
1555 West 2nd Street
Indianapolis, IN 46123
Phone: 317-123-4567
Fax: 317-123-4568
Cesia G. Eves, #12345-67
Ivy Injury Law, Inc.
1555 West 2nd Street
Indianapolis, IN 46123
Phone: 317-123-4567
Fax: 317-123-4568
Counsel for Plaintiffs
Your preview ends here
Eager to read complete document? Join bartleby learn and gain access to the full version
- Access to all documents
- Unlimited textbook solutions
- 24/7 expert homework help