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REGINALD D. HOWZE,
Plaintiff
v.
IN THE COUR'r OF COMMON PLEAS Of'
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9)~ ~''f't CIVIL TERM
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
LARRY W. DALTON and
MID-STATE SYSTEM, INC.,
Defendants
COMPLAINT
AND NOW, comes the Plaintiff, Reginald D. Howze, by and
through his attorneya, Law Offices of Michael J. Hanft, and aver a
the follcwing cause of actionl
1. The Plaintiff is Reginald D. Howze, an adult individUal
who rea ides at 621 Nicholas street, Waterloo, IA 50707.
2. The Defendant is Larry W. Dalton, an adult individual
who currently resides at 1313 Jewett Drive, Zainesville, OH
43701.
3. The Defendant Mid-State Systems, Inc., is a corpcration
organized and existing under the laws cf the state of Ohio with
its principal plaoe of business at 9455 Lanoaster Road, Pepron,
OH 43025.
4. At all times relevant hereto, Larry W. Dalton was an
agent and employee of Defendant Mid-State Syatems, Ino.
5. The events hereinafter oomplained of occurred on or
about March 24, 1993, at approximately 6155 p.m., in Silver
Spring Township, Cumberland county, Pennsylvania, in the parking
lot of the carlisle Texaco truck stop.
6. At said time and place, Plaintiff was occupying a
parked traotor trailer in a general northbound direction.
I
7. At eaid time and plane, Defendant, Larry W. Dalton, was
travelling in a general ~estbound direction in said parking lot.
8. At said time and place, the Defendant, Larry W. Dalton,
struck Plaintiff's parked tractor trailer at the front left
portion of the oab.
9. Plaintiff's injuries and damages set forth herein were
the direct and proximate result of the negligence Defendant,
Larry W. Dalton, and the negligence of Defendant, Mid-State
Systems, Ino., through its agent and employee Larry W. Dalton,
then and there ocourring.
10. Defendant, Larry W. Dalton, was negligent generally and
in the following particulars 1
a. In operating his vehiole in a reckless manner,
b. In failing to maintain a proper lOOk-cut,
O. In failing to have his vehicle under proper control,
d. In operating his motor vehicle in manner which was in
violation of the Laws of the commonwealth of
Pennsylvania,
e. In striking a parked vehicle,
f. In otherwise failing to exercise that regard and care
to the rights and safety of Plaintiff required of
Defendant under the law,
q. In failing to aot reasonably under the ciroumstance.,
and
h. In failing to stop before colliding with Plaintiff'.
parked vfthiole.
" ,
11. Defendant, Mid-State Systems, Inc., through its agent.
and employees, Larry W. Dalton, wae negligent generally and in
the following particularsl
a. In operating his vehiole in a reoklese manner,
b. In failing to maintain a proper look-out,
o. In failing to have his vehicle under proper oontrol,
d. In operating his motor vehiole in manner whioh wae in
violation of the Laws of the commonwealth of
Pennsylvania,
e. In striking a parked vehicle,
f. In otherwi&e failing to exercise that regard and oare
to the rights and safety of Plaintiff required of
Defendant under the law,
g. In failing to act reasonably under the circumstances,
and
h. In failing to stop before colliding with Plaintiff's
parked vehicle.
12. As a direct and proximate result of the negligence of
Defendants, jointly and severally then and there occurring,
Plaintiff sustained the following serious and severe injurie.,
.ome of which may be permanent~
a. Injuries and damages in and about the right shOUlder,
b. Injuries and damages in and about the back and neck,
o. Injuries and damages in and about the left buttook, and
d. Numbness and tingling sensation in his extremities I
13. As a result of the injuries aforesaid, Plaintiff has
been damages as followSI
a. He has sufferod and will continue to suffer great pain,
inconvenience, embarrassment, and mental angUish,