mo4 project a complete complaint
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Ivy Tech Community College, Indianapolis *
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Course
103
Subject
Law
Date
Jan 9, 2024
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docx
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4
Uploaded by DeaconBuffaloPerson876
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,
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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.
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Madison Groves
LEGS103
MO4: Project A Complete Complaint
9.
Speedman drove a 2018 Ford F250.
10. Sam’s vehicle also sustained damage in the accident, but he was not injured.
11. A deer darted across the road in front of Irene’s car, just before the intersection of Arlington and Broadway.
12. Irene had slammed on her brakes to avoid hitting the deer.
13. Sam did not see Irene’s brake lights in time and collided with the rear end of Irene car.
14. Polly Passenger is a co-worker of Sam at the bank
15. She was a passenger in Sam’s vehicle at the time of the accident. Count I: Negligence
1.
Plaintif sustained injuries to her right arm and hand.
2.
Plaintif’s medical care is still ongoing.
3.
Plaintif’s car was damaged
4.
Plaintif’s has missed work due to her injuries.
5.
Defendant had a duty to pay attention to the road while driving a vehicle.
6.
Defendant had the duty to clear of the frost that covered his windshield and keep it cleaned.
7.
Defendant breached his duty by rear-ending Plaintif’s vehicle.
8.
Due to Defendant’s negligence, Plaintif would not have been injured. 3
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Madison Groves
LEGS103
MO4: Project A Complete Complaint
SUMMONS
To defendant: Samual S. Speedman
222 Defendant Drive Bloomington, IN 46555
You are hereby notified that you have been sued by the person named as plaintif and in the Court indicated above. The nature of the suit against you is stated in the complaint which is attached to this Summons. It also states the relief sought or the demand made against you to be the plaintif. An answer of other appropriate response in writing to the complaint must be filed either by you
or your attorney within twenty(20) days, commencing the day after you receive this Summons,
(or twenty-three (23) days if this Summons was received by mail, or a judgement by default maybe rendered against you for the relief demanded by plaintif. If you have a claim for relief against the plaintif arising from the same transaction or occurrence, you must assert it in your written answer.
If you need the name of an attorney, you may contact the Indianapolis Bar Association Lawyer Referral Service (269-2222), or the Monroe County Bar Association Lawyer Referral Service (546-1817).
Dated _______________
____________
Clerk, Monroe Circuit Court
Luann L. Lawyer
Lawyer & Ivy, P.C.
50 W Procedure Place, Suite 509
Indianapolis, IN 26255
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