HomeMy WebLinkAbout97-04929
8. The foregoing accident and all of the inju~ies and
damages set forth hereinafter sustained by Plaintiff Jennifer
Manoni are the direct and proximate result of the negligent,
careless, wanton and reckless manner in which Defendant Schaffer
operated her motor vehicle as follows:
(a) failure to operate her vehicle at a safe speed;
(b) failure to stay within her lane of travel;
(c) failure to drive her vehicle with due regard for
the highway and traffic conditions which were
existing and of which she was or should have been
aware;
(d) failure to keep proper and adequate control over
her vehicle; and
(e) driving her vehicle upon the highway in a manner
endangering persons and property and in a reckless
manner with careless disregard to the rights and
safety of others and in violation of the Motor
Vehicle Code of the Commonwealth of Pennsylvania.
,9. Plaintiff Jennifer Manoni sustained painful and serious
injuries causing permanent disfigurement and a ~erious impairment
of bodily function, which include but are not limited to
cervicalgia, dislocated right hip, fractured right femur, fractured
growth plate, bruised ribs, contusions to the face and head.
10. By reason of the aforesaid inj uries sustained by Ms.
Manoni, she was forced to incur liability for medical treatment,
medications, hospitalization, surgery, and similar miscellaneou8
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expenses in an effort to restore herself to health, an~ claim is
made therefor.
11. Because of the nature of her injuries, Ms. Manoni has
been advised and, therefore, avers that she may be forced to incur
similar expenses in the future, and claim is made therefor.
12. As a result of the aforementioned injuries, Ms. Manoni
has undergone and in the future will undergo physical and mental
suffering, inconvenience in carrying out her daily activities, loss
of life's pleasures and enjoyment, and claim is made therefor.
13. As a result of the aforesaid injuries, Ms. Manoni has
been and in the future will be subject to humiliation and
embarrassment, and claim is made therefor.
14. As a result of the aforementioned injuries, Ms. Manoni
has sustained work loss, loss of opportunity and a permanent
diminution of her earning power and capacity, and claim is made
therefor.
15. As a result of the aforesaid injuries, Ms. Manoni has
sustained uncompensated work loss, and claim is made therefor.
16. Ms. Manoni continues to be plagued by persistent pain and
limitation and, therefore, avers that her injuries may be of a
permanent nature, causing residual problems for the remainder of
her lifetime, and claim is made therefor.
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