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  • Write You - Pennsylvania Injury Lawyer Talks About Philadelphia Injury To Pedestrian

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    ted of the following:

    a. Operating the motor vehicle at a high and excessive rate of speed under the circumstances;

    b. Failing to have the said motor vehicle under proper and adequate control at the time;

    c. Failing to give proper and sufficient warning of the approach of the said vehicle;

    d. Operating the said vehicle wit

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    This article has a sample complaint for a pedestrian who is struck by a car. The complaint also seeks damages for the pedestrian's wife.

    1. Plaintiff, Joshua Williams is an adult individual who resides at the address indicated in the caption.

    2. Plaintiff, Rachel Williams is an adult individual who resides at the address indicated in the caption.

    3. Defendant, Gina Davis is an adult individual who resides at the address indicated in the caption.

    4. On or about October 5, 2006 at approximately 5:15 P.M., plaintiff, Joshua Williams was a pedestrian who was struck by a motor vehicle at or near Curie Boulevard and University Avenue, Philadelphia, Pennsylvania, as a result of which he sustained serious personal injuries, the details of which are hereafter more fully set forth.

    5. At the aforesaid time date and place, the said motor vehicle was owned and operated by defendant, Gina Davis.

    6. The said accident was caused solely by the negligence of defendant, Gina Davis and was due in no manner whatsoever to any actions taken by plaintiff.

    7. Following the accident, plaintiff, Joshua Williams was required to undergo medical attention with the following health care providers:

    Hospital of the University of Pennsylvania

    Benjamin Chang, M.D.

    8. Plaintiff avers that the injuries he sustained in the above accident were the result of the defendant's negligence which consisted of the following:

    a. Operating the motor vehicle at a high and excessive rate of speed under the circumstances;

    b. Failing to have the said motor vehicle under proper and adequate control at the time;

    c. Failing to give proper and sufficient warning of the approach of the said vehicle;

    d. Operating the said vehicle with

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    r>

    3. Defendant, Gina Davis is an adult individual who resides at the address indicated in the caption.

    4. On or about October 5, 2006 at approximately 5:15 P.M., plaintiff, Joshua Williams was a pedestrian who was struck by a motor vehicle at or near Curie Boulevard and University Avenue, Philadelphia, Pennsylvania, as a result of which he sustained serious personal injuries, the details of which are hereafter more fully set forth.

    5. At the aforesaid time date and place, the said motor vehicle was owned and operated by defendant, Gina Davis.

    6. The said accident was caused solely by the negligence of defendant, Gina Davis and was due in no manner whatsoever to any actions taken by plaintiff.

    7. Following the accident, plaintiff, Joshua Williams was required to undergo medical attention with the following health care providers:

    Hospital of the University of Pennsylvania

    Benjamin Chang, M.D.

    8. Plaintiff avers that the injuries he sustained in the above accident were the result of the defendant's negligence which consisted of the following:

    a. Operating the motor vehicle at a high and excessive rate of speed under the circumstances;

    b. Failing to have the said motor vehicle under proper and adequate control at the time;

    c. Failing to give proper and sufficient warning of the approach of the said vehicle;

    d. Operating the said vehicle wit

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    serious personal injuries, the details of which are hereafter more fully set forth.

    5. At the aforesaid time date and place, the said motor vehicle was owned and operated by defendant, Gina Davis.

    6. The said accident was caused solely by the negligence of defendant, Gina Davis and was due in no manner whatsoever to any actions taken by plaintiff.

    7. Following the accident, plaintiff, Joshua Williams was required to undergo medical attention with the following health care providers:

    Hospital of the University of Pennsylvania

    Benjamin Chang, M.D.

    8. Plaintiff avers that the injuries he sustained in the above accident were the result of the defendant's negligence which consisted of the following:

    a. Operating the motor vehicle at a high and excessive rate of speed under the circumstances;

    b. Failing to have the said motor vehicle under proper and adequate control at the time;

    c. Failing to give proper and sufficient warning of the approach of the said vehicle;

    d. Operating the said vehicle wit

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    f.

    7. Following the accident, plaintiff, Joshua Williams was required to undergo medical attention with the following health care providers:

    Hospital of the University of Pennsylvania

    Benjamin Chang, M.D.

    8. Plaintiff avers that the injuries he sustained in the above accident were the result of the defendant's negligence which consisted of the following:

    a. Operating the motor vehicle at a high and excessive rate of speed under the circumstances;

    b. Failing to have the said motor vehicle under proper and adequate control at the time;

    c. Failing to give proper and sufficient warning of the approach of the said vehicle;

    d. Operating the said vehicle wit

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    ted of the following:

    a. Operating the motor vehicle at a high and excessive rate of speed under the circumstances;

    b. Failing to have the said motor vehicle under proper and adequate control at the time;

    c. Failing to give proper and sufficient warning of the approach of the said vehicle;

    d. Operating the said vehicle without due regard for the rights, safety and position of the plaintiff at the point aforesaid;

    e. Violating the various ordinances of the City of Philadelphia and the statutes of the Commonwealth of Pennsylvania pertaining to the operation of motor vehicles;

    f. With plaintiff in plain view, failing to exercise care and vigilance so as to avoid hitting plaintiff;

    g. Passing a stopped bus and over double yellow lines before striking the body of the plaintiff;

    h. Otherwise failing to exercise due care under the circumstances.

    COUNT I

    JOSHUA WILLIAMS v. GINA DAVIS

    9. The allegations contained in paragraphs 1 through 8 above are incorporated by reference as though set forth in full.
    10. As the result of the defendant's negligence, plaintiff sustained severe personal injuries including but not limited to left fifth finger fracture, contusions, shoulder and knee pain, shock and injury to his nerves and nervous system, and he was otherwise injured.

    11. As a result of this accident, the plaintiff became sick, sore, lame and incurred physical pain all of which may continue in the future.

    12. As a further result of this accident, the plaintiff has suffered great pain and agony and will continue to suffer the same in the future.

    13. As a further result of this accident, the plaintiff has suffered an injury which is in full or part a cosmetic disfigurement which may be p

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