Essay on Misc

788 Words Jan 8th, 2013 4 Pages
Assume that you work for attorney Tara Jolans of Adams & Tate, 1000 Town Center, Suite 500, White Tower Michigan. Jolans has decided to represent Sandra Nelson in her lawsuit against David Namisch. Based on the following information, draft a complaint to be filed in the U.S. district Court for the Eastern District of Michigan. Sandra Nelson is a plaintiff in a lawsuit resulting from an automobile accident. Sandra was turning left at a traffic light at the intersection of Jefferson and Mack streets, while the left-turn arrow was green, when she was hit from the side by a car driven by David Namisch, who failed to stop at the light. The accident occurred on June 3, 2011, at 11:30 p.m. David lives in New York, was visiting his family in …show more content…
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GENERAL ALLEGATIONS 5. That on June 3, 2011, at approximately, 11:30 p.m., the Plaintiff, Sandra Nelson, was exercising reasonable care in driving her car while making a left turn at a traffic light, while the left-turn arrow was green, at the intersection of Jefferson and Mack Street, when a vehicle driven by the Defendant, David Namsich, failed to stop at the light and collided into the side of the Plaintiff’s vehicle. 6. That prior to the collision, the Defendant, David Namsich, was drinking and was allegedly intoxicated. 7. That the Defendant, David Namsich, owed the plaintiff, Sandra Nelson, the following duties of care: A. Duty to stop at the red stop light at the intersection of Jefferson and Mack Street. B. Duty to wait until the stop light turned green to proceed across the intersection. C. Duty not to drive his motor vehicle in a reckless, careless, or heedless manner with willful and wanton disregard for the safety and rights of others. 8. That the Defendant, David Namsich, breached each of the above duties, and violated the following: D. That he was guilty of reckless driving within the meaning of section 9.2326 of the statutes of the State of Michigan. E. That he was guilty of careless and negligent driving within the meaning of section 9.2326(2) of the Michigan

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