HomeMy WebLinkAbout96-04979
~
:l
~
~
~
~
~. :\
I
i
,
~
,,:l
/
/
i
[
f
!
I
!
!
i
~
,
I
:-.. i
I
.. -
.
,
i
/
.
~
J
~
J
"'~
0'"
"".....
""...
~~
':3. '~':)
. ../l
~'.n '.Ii
.
l'I
lr.
-;
1--=
~~;
, .
.'
~f
~t.
f
,.
L'
N
J<!("
.~~
~G
,....
,)~j
~;.?::i.
'j
U
o
(::
i
--
0.:
0'\
I
(L
L'>J
c,,;
\.0
0-0
~
r
\j
z
is '"
. --
lIl<ill Iii It .. I
U~Pi!~
...Il!~!::
g<....~,..
lO ~ . . I I
jllli~.E
c:i~ i
I = I ~
ill <<
= lI:
.
.
',-',W',,,,,,,,,
~, """ ,,,,,,,. "') >
~~.._-.-~"",,_.~~
'"',".",w.".".,",,,,,'.W_~"
""""","'-""",-~"",,,,,,,,..".,.-....,,,,,-,...-
-~-..
.
.
.
.
. PLEADINGS! ,.,.J04""."'I'/S-14.IH/,t
e. by failing to keep a reasonable lookout for other
vehicles lawfully on the roadways;
f. by operating his vehicle with careless disregard for
other persons and vehicles on the highway,
specifically the Plaintiff;
g. by failing to operate his vehicle with due regard
and due care for the safety of others on the
highway;
h. by failing to drive his vehicle at a safe speed
under the conditions;
i. by failing to drive his vehicle within the posted
speed limit for that roadway; and
j. by operating his vehicle in a manner in violation
of the Pennsylvania Motor Vehicle Code.
8. As a direct and proximate result of the aforesaid
accident and negligence of Defendant, Plaintiff has sustained
severe injuries which include, but are not limited to, the
following:
a. severe strain/sprain of the cervical spinel
b. right shoulder contusion and sprain;
c. contusion of the right knee;
d. tear of the lIIltdial _nhcus of the riqht knee and/or
aqgravation of underlying degenerative medial
meniscus fraying;
1
'PLEADI~OS/,."J""j-v"H'4 fN/'/'
e. chondromalacia of the medial femoral condyle and
tibial articular surface (medial compartment) and/or
aggravation of pre-existing chondromalacia in that
area; and
f. various other severe contusions, bruises and
abrasions.
9. As a result of his injuries, Plaintiff has suffered, and
will in the future continue to suffer, severe physical pain, mental
anguish and Buffering, humiliation, inconvenience, embarrassment,
scarring and loss of life's pleasures.
10. As a direct and proximate result of the aforesaid
accident and related injuries, Plaintiff has been damaged as
followsl
a, he has been, and will continue to be, limited in his
normal daily activities;
b. he has suffered, and will continue to suffer, severe
physical pain;
c. he has suffered, and will continue to suffer. great
nervous and emotional distress. mental anguish and
suffering;
d. he has suffered. and will continue to suffer.
illlp81rlllent to his general health. strengtb and
vitality;
"