Emily Besse                                                   *          IN THE

            Plaintiff                                               *          CIRCUIT COURT

v.                                                                     *          FOR

Curtis P. Monrow                                           *          BALTIMORE CITY

            Defendant                                          *          CIVIL ACTION NO.:

            *          *          *          *          *          *          *          *          *          *          *

COMPLAINT


      Plaintiff, Emily Besse by her attorneys, Ronald V. Miller, Jr., Laura G. Zois, and Miller & Zois, LLC, and sues the Defendants, Curtis P. Monrow and GEICO, and in support thereof states as follows:


JURISDICTION AND VENUE

  1. That the Plaintiff currently resides in Baltimore, Maryland.
  2. That the Defendant currently resides in Woodlawn, Maryland.
  3. That the Co-Defendant, GEICO, currently conducts business in the state of Maryland.
  4. That on or about November 15, 2002, the Plaintiff was operating a motor vehicle traveling southbound on Hilton Parkway near its intersection with Edmondson Avenue in Baltimore, Maryland.
  5. At the same time and place, the Defendant, Curtis P. Monrow, was operating a motor vehicle traveling southbound on Hilton Parkway near its intersection with Edmondson Avenue in Baltimore, Maryland.


COUNT I - NEGLIGENCE


The Plaintiff incorporates by reference herein all of the above paragraphs.

  1. The Defendant, Curtis P. Monrow, operated his vehicle in a negligent, reckless and careless manner by failing to maintain proper control of the vehicle, causing the vehicle to strike the Plaintiff's vehicle.
  2. The collision was caused solely by the negligence and lack of due care on the part of the Defendant with no negligence on the part of the Plaintiff contributing thereto.
  3. As a direct and proximate cause of the accident, the Plaintiff has suffered serious and grievance physical injuries and these injuries are permanent in nature and caused Plaintiff to suffer continuous pain since the day of the accident.
  4. As a further proximate result of the accident, the Plaintiff has been required, and will continue to undergo medical care and numerous diagnostic procedures with associated pain and discomfort.
  5. As a further and proximate result of the accident, the Plaintiff has suffered, and will continue to suffer anxiety, fear, and emotional stress associated with the accident and his/her injuries.
  6. As a further and proximate result of the accident the Plaintiff has incurred, and will continue to incur substantial medical expense and loss of employment income.
  7. As a further direct and proximate result of the accident and the Defendant’s negligence, the Plaintiff has incurred substantial damage to her vehicle and loss of the use of her vehicle.

    WHEREFORE, Plaintiff demands judgment be entered against the Defendant, Curtis P. Monrow, for compensatory damages in the full and just amount of FIVE HUNDRED THOUSAND DOLLARS ($500,000.00), plus costs, pre-judgment interest, and post-judgment interest.


COUNT II - BREACH OF CONTRACT


The Plaintiff incorporates by reference herein all of the above paragraphs.

  1. At the time of the accident, the vehicle operated by the Defendant, Curtis P. Monrow, was uninsured, or in the alternative, that any insurance in force on the vehicle did not and does not, provide adequate coverage for the claims asserted by the Plaintiff.
  2. At the time of the accident, the Plaintiff had in force a policy of automobile insurance issued by the Co-Defendant, GEICO. Said policy of insurance contained a provision for uninsured motorist coverage which provided, among other things, insurance coverage for losses and damages sustained in accidents which were caused by the negligent operation of a vehicle by third persons, when that vehicle is uninsured at the time of the accident, and the third person is not otherwise entitled to coverage.
  3. The Defendant, GEICO, has breached its contract with the Plaintiff. The Co-Defendant, GEICO, has failed to make any payment under the Plaintiff’s uninsured motorist provision of the Plaintiff’s policy.

    WHEREFORE, the Plaintiff, Emily Besse, demands judgment be entered against the Defendant, GEICO, for compensatory damages in the full and just amount of ONE HUNDRED THOUSAND DOLLARS ($100,000.00), plus costs, pre-judgment interest, and post- judgment interest

                                                                                Respectfully submitted,

                                                                                MILLER & ZOIS, LLC



                                                                                Ronald V. Miller, Jr.                                                                                                                 Laura G. Zois
                                                                                Empire Towers, Suite 615
                                                                                7310 Ritchie Highway
                                                                                Glen Burnie, Maryland 21061
                                                                                (410)553-6000
                                                                                (410)760-8922 (Fax)
                                                                                Attorneys for the Plaintiff


PLAINTIFF’S REQUEST FOR JURY TRIAL

The Plaintiff, Emily Besse, pursuant to Maryland Rule 2-325, prays a trial by jury on all issues.

Related Links
Other Jurisdictions