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PA MVA Complaint Sample

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					         IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY
                            PENNSYLVANIA


Plaintiff’s Name,                           CIVIL DIVISION

        Plaintiff,                          NO:

                                            CODE:001
        vs.
                                            COMPLAINT IN CIVIL ACTION
Defendant’s Name,

        Defendant.                          FILED ON BEHALF OF:

                                            Plaintiffs

                                            COUNSEL OF RECORD FOR THIS
                                            PARTY:

                                            _____________, Esquire
                                            Pa. I.D. #
JURY TRIAL DEMANDED
                                            PORTNOY & QUINN, LLC
To the within –named Defendant              FIRM #724
You are hereby notified to file a written   Three Gateway Center Suite 2325
response to the enclosed Complaint          401 Liberty Avenue
within twenty (20) days from service        Pittsburgh, PA 15222
hereof or a default judgment may be
entered against you.                        412-765-3800

Portnoy & Quinn, LLC.

BY____________________________
Attorneys for Plaintiff
                                          N O T I CE


       You have been sued in Court. If you wish to defend against the claims set forth in the

following pages, you must take action within twenty (20) days after this Complaint and Notice

are served, by entering a written appearance personally or by the attorney and filing in writing

with the Court your defenses or objections to the claims set forth against you. You are warned

that if you fail to do so, the case may proceed without you and a judgment may be entered

against you by the Court without further notice for any money claimed in the Complaint or for

any other claim or relief requested by the Plaintiffs. You may lose money or property or other

rights important to you.

       YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.                              IF YOU

SHOULD NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE

THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.


                           ALLEGHENY COUNTY BAR ASSOCIATION
                               LAWYER REFERRAL SERVICE
                                920 CITY-COUNTY BUILDING
                                       GRANT STREET
                                   PITTSBURGH, PA 15219
                                        (412) 261-5555



                                            PORTNOY & QUINN, LLC


                                            BY______________________________
                                                 _________________, Esquire
                                                 Counsel for Plaintiffs
                                  COMPLAINT IN CIVIL ACTION

      1.       Plaintiff’s Name (hereinafter "Plaintiff") is an adult individual resident of the City of

_________________, County of Allegheny, Commonwealth of Pennsylvania.

      2.       Defendant’s Name (hereinafter "Defendant") is an adult individual resident of the

County of Allegheny, Commonwealth of Pennsylvania.

      3.       The events hereinafter complained of occurred on ____date__ at or around 2:30 p.m.

on __location_____, County of Allegheny, Commonwealth of Pennsylvania.

      4.       At said time and place, Plaintiff was driving a motor vehicle on ____road____ and

was approaching a yield sign.

      5.       At said time and place, Defendant was operating a motor vehicle traveling directly

behind Plaintiff.

      6.       At the aforementioned time and place, a tractor-trailer in front of Plaintiff braked.

      7.       At that time, Plaintiff applied her brakes, bringing her vehicle to a complete stop so as

to avoid colliding, striking and running into the rear of the tractor-trailer in front of her.

      8.       At that time, Defendant ran into, struck and collided with the rear end of the

Plaintiff’s vehicle, causing Plaintiff to be thrown in and about her vehicle thereby sustaining

certain personal injuries as enumerated below.

                                      COUNT I—NEGLIGENCE
                                 Plaintiff’s Name v. Defendant’s Name

      9.       Plaintiff incorporates by reference all other paragraphs of this Complaint as if fully

set forth herein and further alleges as follows:

    10.        All of the resultant losses, damages, and injuries sustained by Plaintiff were the direct

and approximate result of the negligence of Defendant, generally and in the following

particulars:
            a. In operating said motor vehicle at an excessive rate of speed under the
               circumstances; and/or

            b. In not watching or looking where said motor vehicle was being operated;
               and/or

            c. In failing to watch the road in front of said motor vehicle; and/or

            d. In failing to have said motor vehicle under proper control; and/or

            e. In failing to have her motor vehicle under proper control when
               approaching traffic ahead of said vehicle; and/or

            f. In operating said motor vehicle in such a reckless manner so as to be
               unable to stop within the assured clear distance ahead; and/or

            g. In failing to have the brakes and braking mechanism on said motor vehicle
               in proper working order and/or in failing to properly, promptly and
               adequately operate the brakes and braking mechanism of said motor
               vehicle; and/or

            h. In operating said motor vehicle in such a reckless, careless, wanton and
               negligent manner so as to cause or allow same to run into, strike and
               collide with the motor vehicle operated by Plaintiff; and/or

            i. In failing to stop and/or turn aside said motor vehicle or take other
               appropriate action so that the collision between said vehicle and the motor
               vehicle operated by Plaintiff would be avoided; and/or

            j. In failing to respect the rights of Plaintiff to the use of the highway.

    11.     As a direct and proximate result of the foregoing, Plaintiff sustained injuries to her

neck, spine, back, and shoulder, including list specific injury; and the muscles, tissues, ligaments

and tendons extending in and about the aforementioned portions of her body were strained, torn

and/or dislocated, all of which injuries are or may be permanent in nature.

    12.     As a result of said injuries, Plaintiff has been or will be obliged to receive and

undergo medical attention and care and to expend various sums of money or to incur various

expenses, which expenses have or may exceed the sum recoverable under the limits in 75 P.S.

§1711 and may be obliged to continue to expend such sums or incur such expenditures for an

indefinite time in the future.
    13.    As a further result of said injuries, Plaintiff has suffered, and may continue to suffer, a

loss of her earnings and an impairment of her earning capacity and power, which said loss of

income and/or impairment of her earning power has or may exceed the sums recoverable under

the limits in 75 P.S. § 1711.

    14.    As a further result of said injuries, Plaintiff has suffered and/or may suffer physical

and mental anguish and pain, suffering and inconvenience.

    15.    As a further result of said injuries, Plaintiff has suffered and/or may suffer shock and

injury to the nerves and nervous system and has suffered or may suffer emotional distress.

    16.    As a further result of said injuries, Plaintiff has been and/or may be deprived of the

ordinary pleasures of life.

       WHEREFORE, Plaintiff claims damages in a sum in excess of the jurisdictional limits of

a Board of Arbitrators of this Honorable Court.


JURY TRIAL DEMANDED                                   Respectfully submitted,

                                                      PORTNOY & QUINN, LLC



                                                      By_________________________
                                                            ________________, Esquire
                                                            Attorneys for Plaintiff

				
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Description: Sample Motor Vehicle Crash Complaint for Pennsylvania