HomeMy WebLinkAbout96-03207
S. At the same time. Defendant Gibbons was operating a vehicle, that he had
rented from Defendant Thrifty Car Rental, south on Route 896, when he crossed into
Plaintiff's lane of travel and caused the collision.
6. At all times material hereto, Defendant Thrifty Car Rental acted through its
agents. servants and/or employees within the course and scope of their agency or
employment.
7, At all times material hereto, the subject vehicle, operated by Defendant
Gibbons, was owned by Defendant Thrifty Car Rental and operated and controlled by
Defendant Gibbons.
8. As a result of the collision, Plaintiff suffered severe and disabling injuries,
including injuries to her nerves, bones, muscles, joints and fascia, scarring, pain and
suffering, mental and emotional distress, which may be continuing in nature.
9. As a result of her injuries, Plaintiff incurred medical bills and expenses for
care, treatment and rehabilitation, lost earnings and/or earning capacity, and suffered loss of
life's pleasures and diminution of daily activities, which may be continuing.
10. As a result of her injuries, Plaintiff sustained embarrassment and
humiliation, which may be continuing in nature, and she has suffered loss of and damage to
her motor vehicle.
COUNT I
PLAINTIFE...Y....DEFENDANT GIBBONS
11. Plaintiff incorporates herein by reference the allegations of paragraphs 1
through 10 as if fully set forth at length,
2
12. Plaintiff's injuries and damages were due to the negligence of Defendant,
including:
A. Failing to keep a proper lookout;
B. Failing to keep his vehicle under control;
C. Traveling at an unsafe speed;
D. Operating his vehicle in Plaintiff's lane of travel;
E. Failing to yield the right-of-way;
F. Failing to warn Plaintiff of an unreasonable risk of harm;
G. Striking Plaintiff's vehicle;
H. Violating state laws and local ordinances relative
to the above allegations of negligence.
WHEREFORE, Plaintiff demands judgment against Defendant, individually,
jointly and/or severally, in an amount in excess of $35,000.00, exclusive of interest, costs
and delay damages.
COUNT II
PLAINTIFF v. DEFENDANT WELCOME CORPORATION
13. Plaintiff incorporates herein by reference the allegations of paragraphs 1
through 12 as if fully set forth at length.
14. Plaintiff's injuries and damages were caused by the negligence of
Defendant, individually, jointly and/or severally, including:
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