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4, This accident resulted solely from the negligence and recklessness of the
Defendant herein and was due In no manner whatsoever to any act or failure to act on
the part of the Plaintiff, James E, Reid, Jr,
5, The negligence and recklessness of the Defendal')t consisted of the
following:
a. Failure to properly operate and control her motor vehicle,
b, Driving at an excessive rate of speed under the
circumstances,
c, Failing to observe and obey the stop light directed at her lane
of travel.
d, Following another vehicle more closely than Is reasonable
and prudent under the circumstances,
e, Operating her vehicle in violation of the statutes of the
Commonwealth of Pennsylvania pertaining to the operation
of vehicles on the streets and highways,
f, Failing to keep a reasonable and proper look out on the
highway for other vehicles,
g, Failing to stop her vehicle within assured clear distance
ahead,
h, Failing to exercise a degree of care, caution and skill
reasonable required under all the circumstances.
6, As a result of this accident, Plaintiff has suffered injuries which are or may
be serious, including severe neck and back pain, C4-C5 impingement bilaterally with
sensory radiculopathy, myofacial pain, and various other ills and injuries,
7, As a further result of this accident, Plaintiff has been obliged to receive and
undergo medical attention and care,
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