Manchester NH Motorcycle Accident
Feniger & Uliasz Lawyers
Hillsborough County Superior Court
1. The Plaintiff is an individual residing in the City of Manchester, State of New Hampshire 03103 and was at all relevant times hereto lawfully married.
2. The Plaintiff, wife, is an individual residing in the City of Manchester, State of New Hampshire 03103 and was at all relevant times hereto lawfully married to injured Plaintiff.
3. The Defendant is an individual and on information and belief a resident of the City of Manchester, State of New Hampshire 03103 and was at all relevant times hereto, the operator of motor vehicle traveling on a public right of way within the city of Manchester, New Hampshire.
COUNT I (Negligence)
4. On or about April 27, 2009 the Defendant, while in the operation of a motor vehicle , suddenly and without warning executed a left turn into the path of the Plaintiff, who was at the time operating a motorcycle within his designated lane of travel, causing a collision between said vehicles.
5. At all times relevant hereto the Defendant owed a duty to the Plaintiff to use reasonable care in the operation of his vehicle under the circumstances then and there existing.
6. The Defendant breached the duty of care as owed to the Plaintiff by failing to operate the subject vehicle with reasonable care, by failing to keep a proper lookout, by failing to engage a directional or provide other lawful warning, by failing to yield the right of way and by operating said vehicle so as to collide with the Plaintiff.
7. That as a direct and proximate result of the negligence of the Defendant, as herein alleged, the Plaintiff was caused to sustain severe physical injuries and conscious pain and suffering.
8. That as a direct and proximate result of the negligence of the Defendant as herein alleged, the Plaintiff has been caused to incur medical expenses for treatment of injuries sustained and is likely to incur future medical expenses.
9. That as a direct and proximate result of the negligence of the Defendant as herein alleged, the Plaintiff has been caused to lose wages.
10. That the Plaintiff bears no fault for the injuries and damages as alleged.
WHEREFORE, Plaintiff requests:
1. Judgment for damages plus interest from the date of his cause of action.
2. Reasonable cost and attorney’s fees.
3. For such other and further relief as this Honorable court may deem just and proper.
The Plaintiff demands a jury hear his cause.
COUNT II (Loss of Consortium)
11. This count on behalf of the plaintiff, wife, is for loss of consortium and incorporates by reference herein paragraphs one through 10 and states further;
12. That on April 27, 2009 wife was lawfully married to injured Plaintiff living together as husband and wife.
13. That as a direct and proximate result of the negligence of the Defendant and injuries sustained by her husband as hereinbefore alleged, wife has been deprived of the love, affection, society, companionship and the income of her Husband.
14. That as a direct and proximate result of the negligence of the Defendant and injuries sustained by her husband as hereinbefore alleged, wife has been caused to suffer a loss of income
WHEREFORE, Plaintiff requests:
4. Judgment for damages plus interest from the day of her cause of action.
5. Reasonable cost and attorney’s fees.
6. For such other and further relief as this Honorable court may deem just and proper.
The Plaintiff demands a jury hear her cause.
