HomeMy WebLinkAbout95-05470
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WANDA D. HALTERMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
v.
NO. CIVIL
CIVIL ACTION - LAW
WILLIAM P. VILLOTT,
Defendant
JURY TRIAL DEMANDED
COMPLAINT
1. The Plaintiff, Wanda D. Halterman, is an adult individbal
residing at 124 Barnwood Place,
Pennsylvania, 17112.
2. The Defendant, william P. Villott, is an adult individual
,
Harrisburg,
Dauphin county,
,
who currently resides at 114 Regency Woods North, carlisle,
Cumberland county, Pennsylvania, 17013.
3. On or about November 5, 1993, at approximately 9:40 a.m.,
the Plaintiff was operating a vehicle in a general westerly
direction on the wertzville Road near the intersection of '1;:he
~
Wertzville Road with Rich Valley Road in Cumberland county.
4. At the same time and'place, the Defendant was operating a
vehicle, also in a general westerly direction on Wertzville Road ~t
some distance to the rear of Plaintiff's vehicle.
5. As Plaintiff approached the intersection with the Rich
Valley Road, Plaintiff slowed down her vehicle, put her left turn
signal on and came to a stop in order to make a left turn onto Rich
Valley Road.
6, The Defendant negligently continued in a westerly
direction and violently collided with the rear of Plaintiff's
vehicle.
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7. The collision was the result of the carelessness and
negligence of the Defendant and consisted of the followingl
(a) In operating his vehicle in careless disregard of the
rights and safety of the Plaintiff and others,
(b) In operating his motor vehicle in disregard to the left
turn signal of the Plaintiff and the Plaintiff's
brakelights which should have indicated to the Defendant
that Plaintiff was slowing down and stopping to make a
left turn,
(c) In operating his motor vehicle at an excessive rate of
speed under the circumstances,
(d) In following too closely to the rear of Plaintiff's
vehicle so as not to enable the Defendant to stop his
vehicle without colliding with the vehicle of the
Plaintiff,
(e) In failing to keep his vehicle under control at all times
so as to avoid the collision with the rear of Plaintiff's
vehicle, and
(f) In failing to keep his eyes on the road in front of him
so as to enable him to adjust to the circumstances
without causing a collision.
8. Solely because of the negligence of the Defendant, above
described, Plaintiff suffered severe personal injuries, the entire
extent of which is not presently known, and which includes but is
not limited to, cervical sprains and strains, contusions to the
left hand and left knee, spasms of radiating back pain, major
headaches and ear ringing and tenderness of the neck muscles,
numbness of the legs with leg pain, a central disc herniation,
together with a severe shock to her nerves and nervous system, by
reason of which she has been made to undergo, and may and probably
will in the future undergo, great mental anguish and physical pain
and SUffering, some of the aforesaid injuries probably being
permanent in nature.
9. As a result of the injuries, Plaintiff has already been
obliged to receive and undergo medical attention, hospitalization
and care, and to incur various expenses necessitated for the
treatment and care of said injuries.
10. As a result of the injuries, Plaintiff has or may sutter
a loss of earnings and impairment of earning capacity and power.
WHEREFORE, Plaintiff claims damages from the Defendant in an
amount in excess ot $10,000.00, plus other costs as the law may
allow.
Datel 1t?/6/~
Respectfully SUbmitted,
~Jk~-
R. Mark Thomas, Esquire
54 E. Main street
Mechanicsburg, PA 17055
(717)697-4650
1.0./1 41301
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