Sample Uninsured Motorist Complaint Against GEICO

Emily Bellamy
- Plaintiff

v.

Curtis P. Sears
- Defendant

IN THE CIRCUIT COURT FOR BALTIMORE CITY
CIVIL ACTION NO.:

UNINSURED MOTORIST COMPLAINT

Plaintiff, Emily Bellamy by her attorneys, Ronald V. Miller, Jr., Laura G. Zois, and Miller & Zois, LLC, and sues the Defendants, Curtis P. Sears and GEICO. In support of this uninsured motorist lawsuit against GEICO, the Plaintiff states as follows:

JURISDICTION AND VENUEum complaint
  1. Plaintiff resides in Baltimore, Maryland. She has lived in Baltimore her entire life.
  2. Defendant currently resides in Rockville, Maryland.
  3. Co-Defendant, GEICO, currently conducts business in the state of Maryland.
  4. On July 15, 2015, the Plaintiff was driving in her car on Lombard Street near its intersection on Calvert Street in downtown Baltimore.
  5. At the same time and place, the Defendant, Curtis P. Sears, was operating a truck traveling north on Calvert Street.
COUNT I - NEGLIGENCE

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

  1. This is an action for losses caused by the the negligent operation of a motor vehicle. Defendant, Curtis P. Sears, 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 instead of waiting to proceed from a red light.
  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 motor vehicle crash, the Plaintiff has suffered serious and grievious physical injuries and these injuries are permanent in nature and caused Plaintiff to suffer continuous pain since the day of the accident.
  4. Uninsured Motorist Cases
  5. As a direct and proximate result of the crash, the Plaintiff has been badly injured. Among other injuries, she has broken her leg in three different places. She has been required, and will continue to undergo medical care and numerous diagnostic procedures with associated pain and discomfort. These are serious and permanent injuries. She has been prevented from performing the functions of her job, she has suffered and will continue to suffer great pain of body (and mind); has sustained permanent disability, deformity and loss of earning capacity. She has incurred signficant medical bills.
  6. 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.
  7. 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.
  8. 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 against Defendant Sears in an amount greater than $75,000.00, jointly and severally, plus costs, pre-judgment interest, and post-judgment interest as this Court deems appropriate. [Miller & Zois Note: this is the appropriate language now in Maryland. We no longer need to request a specific amount when filing suit in a Maryland Circuit Court.]

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. Sears, was uninsured. After discovering this, Plaintiff timely notified GEICO of the motor vehicle collision and the fact that Mr. Sears had no automobile insurance. She complied to the letter of all of the terms, terms, and obligations of her policy. Of course, she wanted to receive the compensation she was entitled to recovery.
  2. At the time of the accident, the Plaintiff had in force a policy of automobile insurance issued by the Co-Defendant, GEICO. Ms. Bellamy is the principal insured. She has been a GEICO customer for 17 years. This insurance policy 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 GEICO breached its contract with the Plaintiff. The company has not, as promised, paid the Plaintiff the value of her claim as the uninsured motorist provision of her policy dictates.

WHEREFORE, Plaintiff demands judgment against GEICO in an amount greater than $75,000.00, jointly and severally, plus costs, pre-judgment interest, and post-judgment interest as this Court deems appropriate.

Respectfully submitted,
MILLER & ZOIS, LLC

Ronald V. Miller, Jr.

Miller & Zois
Alex Brown Building
One South Street, 24th Floor
(410)779-4600
(410)760-8922 (Fax)
Attorneys for the Plaintiff

PLAINTIFF’S REQUEST FOR JURY TRIAL

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

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