IN THE COURT OF COMMON PLEAS OF LUCAS COUNTY, OHIO

PAULA PLAINTIFF 1234 Secor Road Toledo, OH 43613 Plaintiff,

v.

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) ) )

Case No. CI- __________________

JUDGE ______________________

COMPLAINT FOR NEGLIGENCE WITH JURY DEMAND

DAVID DEFENDANT 5678 Monroe Street Toledo, OH 43614

Defendant

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Gary Horn (0016297)

Dewey, Cheatham, and Howe Law Office

1796 Indian Wood Circle Maumee, OH 43537 (419) 866-0261 Attorney for Plaintiff

______________________________________________________________________________

Now comes Plaintiff, Paula Plaintiff, by and through counsel, Gary Horn, and alleges and avers the following:

GENERAL ALLEGATIONS

1. That at all relevant times, Plaintiff, Paula Plaintiff, resided in Lucas County at 1234 Secor Road, Toledo, Ohio 43613. 2. That at all relevant times, Defendant, David Defendant, resided in Lucas County at 5678 Monroe Street, Toledo, OH 43614. 3. That on April 8th, 2006, Ms. Plaintiff was driving home from the shopping mall. 4. That Ms. Plaintiff was stopped at the intersection of Monroe and Whiteford Roads, waiting for her light to turn green. 5. That Mr. Defendant failed to stop and struck Ms. Plaintiffs car. 6. That because of the defendant's negligent driving and failure to stop, Ms. Plaintiffs car was struck and she sustained several injuries.

COUNT ONE: NEGLIGENCE

7. Plaintiff incorporates herein the allegations previously stated in Paragraphs 1 - 6 and further alleges Defendant owed a duty to Plaintiff to properly and safely operate his vehicle in accordance with the Motor Vehicle Laws of Ohio. 8. Plaintiff further alleges that Defendant breached his duty by failing to properly and safely operate his vehicle in accordance with the Motor Vehicle Laws of Ohio. As a proximate cause of the defendant's negligent driving and failure to stop, Plaintiff spent many weeks attending physical therapy, incurred medical expenses and vehicle repair costs, lost wages, pain and suffering (present and future), and disruption of lifestyle.

WHEREFORE, Plaintiff respectfully prays for judgment on the above mentioned counts against Defendant, David Defendant, for an award of damages in a sum of money in excess of Thirty Thousand Dollars, adequate to compensate her for emergency room expenses, ambulance service expenses, physical therapy expenses, medical expenses, repair costs of her car, her lost wages, attorneys fees, court costs, and such other relief as the Court deems just and equitable.

Respectfully submitted, ___________________________ Gary Horn Attorney for Plaintiff

JURY DEMAND Now comes the Plaintiff and demands a jury on all issues triable by right before a jury. ___________________________ Gary Horn Attorney for Plaintiff