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Jessica White (008888)

White, Wilson, & McDuff


Federal Plaza Building, Suite 700
Third and Market Streets
Provo, UT 84604
Telephone (801) 344–0000
Facsimile: (801) 344-1100
jessicaW@wwmd.com
Attorney for Plaintiff

IN THE FOURTH JUDICIAL DISTRICT COURT


125 North 100 West, Provo
UTAH COUNTY, STATE OF UTAH

CAROLINE LITTLE and COMPLAINT FOR NEGLIGENCE


CARL LITTLE
Plaintiffs,
v. Civil Case No. ______________

MARSHA PETERSON and


ACME SPECIALTY CAR PARTS, INC. Judge:
Defendants, Commissioner:

Plaintiff, Caroline Little, by and through her undersigned attorney, Jessica White,
White, Wilson & McDuff, as and for its cause of action against the above-named
defendants states and alleges:

1. Plaintiff, Caroline Little, is an individual and is now, and at all times mentioned in
this complaint is resident of Utah County, Utah. The jurisdiction of this court is based
on the amount in controversy in the action, which is more than $10,000. The
Plaintiffs demand trial by jury in this matter.

2. Defendant Marsha Peterson is now, and at all times mentioned in this complaint as an
individual and employee of ACME Specialty Car Parts, Inc.

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3. Defendant ACME Specialty Car Parts, Inc. is now, and at all times mentioned in this
complaint as a corporation organized and existing under the laws of the State of Utah,
with its place of business in Utah County, Utah.

4. Plaintiff is informed and believes, on the basis of that information and belief alleges,
that at all times mentioned in this complaint, the defendant, Marsha Peterson, is the
agent and employee of the codefendant, and in doing the things alleged in this
complaint was acting within the course and scope of that agency and employment.

5. Plaintiff does not know the true names of defendants and therefore sues them by those
fictitious names. Optionally, in addition to language in charging allegations that
includes fictitiously named defendants: Plaintiff is informed and believes the basis of
that information and belief alleges that each of those defendants was in some manner
negligently and proximately responsible for the events and happenings alleged in this
complaint and for plaintiff's injuries and damages.

6. On March 23, 2010, at approximately 3:00 p.m. Plaintiff, Caroline Little, who is
legally blind and uses a white cane for the blind, started to cross the street from the
southeast corner of A Street and Oak Boulevard, Provo, Utah County, Utah, where
there is a traffic light.

7. Marsha Peterson, a delivery driver for Acme Specialty Car Parts, Inc, was
southbound on Oak Boulevard and made a left turn to head east on A Street. The
Defendant completed her turn and struck, the Plaintiff, Caroline Little, with the
Defendants’ company vehicle, which is owned by Acme Specialty Car Parts, Inc.

8. Defendant Peterson operated the delivery vehicle negligently by:

(a) failing to exercise proper lookout


(b) failing to give the right of way to a blind pedestrian carrying a white cane
(c) failing to exercise adequate control of said vehicle
(d) failing to exercise due and adequate care under the circumstances and law
1. As a direct result of the Defendants’ negligence, the Plaintiff was struck down by the
Defendants' delivery vehicle and seriously injured.
2. Because of said negligence, the Plaintiff was admitted to the hospital and kept there
for twenty-five days suffering from scrapes, bruises, a fractured right wrist,
permanent nerve damage to the left leg, a concussion, some neurological damage,

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depression and other maladies, causing her intense pain, great suffering and
considerable inconvenience for her life time.

3. As a consequence of the Defendants’ negligence and the previously mentioned


injuries, the Plaintiff has and will incur substantial monetary losses for hospital and
medical care, domestic services, hospice services, assisted living housing and
property damages to her clothing, cell phone, and a diabetes testing kit.
WHEREFORE, Plaintiff demands judgment against defendants, and each of them in the
amount of two million dollars ($2,000,000,000) together with punitive damages for
emotional distress and pain and suffering in the amount of three million dollars
($3,000,000,000) and the costs and disbursements of this action and for such other relief
as the court may deem just and proper.
COUNT TWO
4. The Plaintiffs hereby allege and incorporate by reference paragraphs 1 through 11 of
Count One.

5. Because of the Defendants’ negligence, Plaintiff William Forrester has suffered a loss
of consortium with his wife, Caroline Little, in the amount of two million dollars
($2,000,000,000).
Wherefore, Plaintiff Carl Little demands judgment against the Defendants in the sum of
two million dollars ($2,000,000,000) and costs for such other relief as this court may
deem just and proper.

DATED this 28 th day of April 2010.

___________________________
JESSICA WHITE
Attorney for Plaintiff

VERIFICATION

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Caroline Little and William Little Plaintiffs in the above-entitled action. I have read the
foregoing COMPLAINT OF NEGLIGENCE and know the contents herein. The same
is true of my own knowledge, except as to those matters which are therein alleged on
information and belief, and as to those matters, I believe it to be true.
I declare under penalty of perjury that the foregoing is true and correct and that this
declaration was executed in Provo, Utah.

__________________
Caroline Little

__________________
Carl Little

Acknowledgment Certificate
State of Utah )
§
County of Utah )

On this 28th day of April, in the year 2010, before me a notary public, personally
appeared Caroline Little and Carl Little, who proved on the basis of satisfactory evidence
to be the person whose name is subscribed to this instrument, and acknowledged she
executed the same. Witness my hand and official seal.

_________________________
NOTARY PUBLIC

Mailing Certificate

I hereby certify that on this 28th day of April 2010, a true and correct copy of the
foregoing document has been mailed, postage prepaid, to the following:

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Attorney for Defendant Marsha Peterson:
Harold Ott ( 112222)
OTT, OTT, & KNUDSEN
444 Front St.
Provo, UT 84604
(801) 344-2000

Attorney for Defendant Acme Car Parts:


Mary Sanders (333208)
2300 Capitol Dr.
Provo, UT 84604
(801) 344-3000

___________________________
Legal Assistant

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