Salem NH Motor Vehicle Accident
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Rockingham County Superior Court
1. The Plaintiff is an individual residing in the Town of Billerica, Commonwealth of Massachusetts and was at all relevant times hereto the owner and operator of a 2002 Ford Explorer.
2. The Defendant is an individual who on information and belief is a resident of the Town of Salem, County of Rockingham, State of New Hampshire and was at all relevant times hereto, the operator of a 1997 Mercury Marquis. On or about April 14, 2007 the defendant while in the operation of the motor vehicle under her control upon Interstate Route 93, within the Town of Salem, NH attempted to execute a lane change without due care or caution and caused said vehicle to strike the vehicle operated by the Plaintiff and further causing the Plaintiff to strike a third vehicle, a 1989 Freightliner Dump truck.
3. At all times relevant hereto the defendant owed a duty to the plaintiff to operate the motor vehicle under her control with reasonable care and caution under the circumstances then and there existing.
4. The defendant breached the duty of care as owed to the plaintiff by failing to operate said motor vehicle with reasonable care, by failing to keep a proper lookout, by executing an unsafe lane change and by striking the vehicle operated by the Plaintiff.
5. That as a direct and proximate result of the negligence of the defendant as herein alleged, the plaintiff was caused to sustain physical injuries and conscious pain and suffering.
6. 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 the treatment of injuries sustained and is likely to incur future medical expenses.
7. That as a direct and proximate result of the negligence of the defendant, as herein alleged, the plaintiff has been caused to lose wages.
8. That the plaintiff bears no fault for the injuries and damages as alleged.
WHEREFORE, Plaintiff requests:
1. Judgment for damages plus interest from the day of her 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 to hear her cause.
