HomeMy WebLinkAbout98-03149
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(k) <\s set forth herein, he operated his vehicle in
violation of the Motor Vehicle Code of the
Commonwea lth of pennsylvania;
6. AS a result of the aforesaid incident and the tortious
conduct of Defendant Raymond L. Kilgore, Plaintiff David L.
Gingrich, Sr. has suffered injuries that include, but are not
limited to:
(a)
(b)
(c)
injuries to his neck;
injuries to his back and spine;
injuries to his upper extremities,
arms and hands;
including his
(d) injury to his cervical discs, including disc
herniations;
(e) injuries to his shoulders;
(f) burns to his neck and shoulder area, occurring as
a result of physical therapy for his injuries; and
(g) aggravation and exacerbation of pre-existing
conditions.
7. As a further result of the incident at issue in this case
and the tortious conduct of the Defendant Raymond L. Kilgore,
plaintiff David L. Gingrich, Sr: has and will suffer and endure
pain, suffering, loss of 1 ife' s pleasures, mental anguish and
emotional distress.
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8, As a further result of the incident at issue in this case
and the tortious conduct of the Defendant Raymond L. Kilgore,
Plaintiff David L. Gingrich, Sr. has suffered a disruption of his
life and his ability to carry out his daily and regular activities,
which now involve pain and discomfort.
9. As a further result of the incident at issue in this caSe
and the tortious conduct of the Defendant Raymond L. Kilgore,
Plaintiff David L. Gingrich, Sr. has suffered a loss of earnings
and earning capaci ty, for Which a claim is made to the extent
permitted by applicable law.
10. As a further result of the incident at issue in this case
and the tortious conduct of the Defendant Raymond L. K.ilgore,
Plaintiff David L. Gingrich, Sr. has and will incur medical
expenses in the future, for which a claim is made herein to the
extent permitted by applicable law.
11. As a further result of the incident at issue in this case
and the tortious conduct of the Defendant Raymond L. Kilgore,
plaintiff David L. Gingrich, Sr. will require continued medical
care in the future and is at risk for further exacerbations of his
injuries and deterioration in his condition and is at risk for
surgery in the future.
WHEREFORE, Plaintiff David L. Gingrich, Sr. demands judgment
in his favor in an amount in excess of 011. amount requiring referral
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