MARY
ANN JOHNSON
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IN THE
Plaintiff
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CIRCUIT COURT
v.
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FOR
JAMES
C. SEXTON
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BALTIMORE CITY
Defendant
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CIVIL ACTION NO.:
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COMPLAINT AND PRAYER FOR JURY TRIAL
Mary Ann Johnson, Plaintiff, by Laura G. Zois, and Miller & Zois, LLC, her attorneys, sues the defendant, James C. Sexton, and in support, states as follows:
PREAMBLE
1. Mary Ann Johnson, Plaintiff, is a resident of Maryland.
2. James C. Sexton, Defendant, is a resident of Maryland.
3. The Defendant regularly visits and is engaged in business
in Baltimore City, Maryland.
4. This action arises from an auto collision which occurred
on May 22, 2000, on Maryland Route 152 at Rockord Road. Both
are public roads in Maryland.
STATEMENT OF FACTS
5. On May 22, 2000, the Plaintiff, Mary Ann Johnson, was carefully
and prudently stopped in her motor vehicle on Route 152, when
her vehicle was violently struck from behind by the Defendant.
6. At the same time, a motor vehicle operated by James C. Sexton,
Defendant, was traveling, and smashed into the Plaintiff’s
vehicle, causing the Plaintiff to sustain serious personal injuries.
COUNT ONE
Plaintiff, Mary Ann Johnson realleges and incorporates by reference all those facts and allegations in paragraphs 1 through 6 above and further alleges:
7. The collision was caused by the recklessness, carelessness
and negligence of the Defendant, James C. Sexton, for that among
other acts and omissions the Defendant:
a. operated the motor vehicle at a high, dangerous and excessive rate of speed under the circumstances then and there existing;
b. failed to reduce speed to avoid a collision;
c. failed to observe due care and precaution and to maintain proper and adequate control of the motor vehicle;
d. failed to keep a proper lookout for other vehicles lawfully upon the highway;
e. failed to exercise reasonable care in the operation of the motor vehicle under the circumstances then and there existing; and
f. In other respects not now known to the Plaintiff but which may become known Prior to or at the time of trial.
8. As a direct and proximate result of the negligence and carelessness of the Defendant, the Plaintiff:
a. suffered serious, painful and permanent bodily injuries, great physical pain and mental anguish, severe and substantial emotion distress, loss of the capacity for the enjoyment of life;
b. was, is and will be required to undergo medical treatment and to incur medical costs and expenses in order to alleviate injuries, pain and suffering;
c. was, is and will be precluded from engaging in normal activities and pursuits, including a loss of ability to earn money and of actual earnings;
d. and, otherwise was hurt, injured and caused to sustain losses.
9. All of the Plaintiff's losses were, are and will be due solely to and by reason of the carelessness and negligence of the Defendant, James C. Sexton, without any negligence or want of due care on the Plaintiff's part contributing thereto.
WHEREFORE, this Plaintiff claims ONE MILLION FIVE HUNDRED THOUSAND
DOLLARS ($1,500,000.00) in damages.
Respectfully submitted,
MILLER & ZOIS, LLC
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Laura G. Zois Empire Towers, Suite1001
7310 Ritchie Highway
Glen Burnie, Maryland 20161
410-553-6000
410-760-8922 - FAX
