HomeMy WebLinkAbout96-03384
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5. At all times relevant to this action, plaintiff Davis was
operating a 1990 Honda Accord bearing Pennsylvania registration
number XCZ306.
6. At all times relevant to this action, Defendant, Tammy S.
Blymire, was operating a 1988 Chevrolet owned by her father,
Defendant Glen F. Blymire, and beuring Pennsylvania registration
number SUB735.
7. On or about February 27, 1993, at approximately 2145
p.m., Plaintiff Davis was travelling eastbound in the passing lane
on Route 581 in Camp Hill, Cumberland County, Pennsylvania.
8. On or about February 27, 1993, at npproximately 2145
p.m., Defendant, Tammy S. Blymire, was travelling down the on-ramp
leading to eastbound Route 581 and attempting to merge onto Route
581.
9. As Defendant, Tammy S. Blymire, attempted to merge onto
eastbound Route 581, suddenly and without warning, Defendant
Blymire swerved into Plaintiff Davis's lane of travel and struck
the right rear side of Plaintiff Davis's vehicle with significant
force. Consequently, the force of the impact pushed the vehicle
operated by Plaintiff Davis into the guard rail.
irritation, cervical and lumbar
instability, and myofascitis.
subluxation,
ligamentous
14. As a result of the negligence of Defendant, Tammy S.
Blymire, Plaintiff Davis has suffered and will continue to suffer
pain and agony in the future to her great detriment and loss.
15. As a result of the negligence of Defendant, Tammy S.
Blymire, Plaintiff Davis incurred lost wages from her job as an
admissions analyst at Harrisburg Hospital.
16. As a result of the negligence of Defendant, Tammy S.
Blymire, Plaintiff Davis was forced to decline a summer positicn at
Appleton Papers for which she had already been hired, but had not
yet begun employment.
17. As a result of the negligence of Defendant, Tammy s.
Blymire, Plaintiff Davis has undergone great pain, discomfort, and
mental anguish, and she will continue to endure the same in the
future to her great physical, emotional, and financial detriment
and loss.
18. As a result of the negligence of Defendant, Tammy S.
Blymire, Plaintiff Davis has and probably \\Iill in the future
continue to suffer a loss of life'~ pleasures, and a claim is made
therefor.
24. The occurrence of the aforementioned accident and the
resulting injuries to Plaintiff Davis were caused directly e.nd
proximately by the negligent entrustment of Defendant, Glen F.
Blymire, generally and more specifically as set forth below:
a) By entrusting the operation of his vehicle to
Defendant, Ta~ny S. Blymire, when he knew or should
have known that Ta~y S. Blymire was an incompetent
and careless driver;
b) In allowing Defendant, Ta~y S. Blymire, to operate
his vehicle in careless disrogard for the safety of
persons or property, in violation of 75 Pa. C.S.A.
S 3714;
c) In allowing Tammy S. Blymire to operate his vehicle
without yielding the legal right of way to
Plaintiff Davis as Defendant entered Route 581 from
a yield sign, in violation of 75 Pa. C.S.A. S 3323
(c) ;
d) In allowing Defendant, Ta~ny S. Blymire, to operate
his vehicle in such a manner that she swerved her
vehicle into Plaintiff Davis's lane of travel when
such movement could not be made in safety, in
violation of 75 Pat C.S.A. S 3309 (1);
strain/sprain, herniated discs at C5-u and L4-5,
irritation, cervical and lumbar subluxation,
instability, and myofascitis.
nerve root
ligamentous
26. As a result of the negligence of Defendant, Glen F.
Blymire, plaintiff Davis has suffered and will continue to suffer
pain and agony in the futuro to her great detriment and loss.
27. As a result of the negligence of Defendant, Glen F.
Blymire, plaintiff Davis incurred lost wages from her job as an
admissions analyst at Harrisburg Hospital.
28. As a result of the negligence of Defendant, Glen F.
Blymire, Plaintiff Davis was forced to decline a su~er position at
Appleton Papers for which she had already been hired, but had not
yet begun employment, and therefore incurred lost wages.
29. As a result of the negligence of Defendant, Glen F.
Blymire, Plaintiff Davis has undergone great pain, discomfort, and
mental anguish, and she wHl continue to endure the same in the
future to her great physical, emotional, and financial detriment
and loss.
30.
Blymire,
As a result of the negligence of Defendant, Glen F.
plaintiff Davis has and pt'obably will in the future
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