District Court Automobile Accident Complaint

IN THE DISTRICT COURT OF MARYLAND FOR HOWARD COUNTY

BRUCE WAYNE

Plaintiff

vs.

JACK CARD

Defendant

* * * * * * *

COMPLAINT

COMES NOW the Plaintiff, Bruce Wayne, by and through her counsel, John J. Cord and Posner & Cord, LLC, and states as follows:

1. That on or about August 17, 2010 at approximately 4:50 p.m., the Plaintiff, Bruce Wayne, was traveling westbound on Route 40 in Ellicott City, Maryland.

2. That at the aforesaid time and place, the Defendant, Jack Card, was operating a vehicle in the same direction, on the same roadway, directly alongside the Plaintiff, Bruce Wayne, when the Defendant, Jack Card, drove his vehicle into the side of the Plaintiff, Bruce Wayne’s vehicle.

3. That said collision took place in Howard, Maryland.

4. That at the time in question, the Plaintiff, Bruce Wayne, acted in a careful and prudent manner without any negligence contributing to the accident.

COUNT I
(Negligence)
(Bruce Wayne v. Jack Card)

5. That the Plaintiff, Bruce Wayne, adopts and incorporates all of the allegations of facts set forth as if fully set forth herein, and in addition states as follows:

6. That on the occasion in question, the Defendant, Jack Card, was negligent in the following particulars, among others, to wit:

a) failure to give time and attention;

b) failure to keep a proper lookout;

c) reckless driving;

d) failure to keep her vehicle under her control;

e) driving at and excessive speed for the conditions existing;

f) failure to yield the right of way to another vehicle;

g) failure to drive in accordance with the laws and motor vehicle regulations of the State of Maryland.

7. That as a direct result of the aforesaid acts of negligence, the Plaintiff, Bruce Wayne, who was at all times exercising due care, was suddenly thrown against the inside of the automobile she was driving. That as a further direct result thereof, the Plaintiff, Bruce Wayne, suffered severe pain and injuries to his body, as well as protracted shock to his nervous system, all of which have caused him pain and mental anguish.

8. That as a further direct result of the negligence of the Defendant, Jack Card, the Plaintiff, Bruce Wayne, has been forced to spend large sums of money for x-rays, doctors, medical treatment and medicine for the treatment of the aforesaid injuries to himself.

9. That as a further direct result of the negligence of the Defendant, Jack Card, the Plaintiff, Bruce Wayne’s vehicle sustained property damage and the Plaintiff, Bruce Wayne, has incurred expenses as a result of said property damage.

WHEREFORE , the Plaintiff, Bruce Wayne, demands judgment against the Defendant, Jack Card, in the amount of Fifteen Thousand Dollars ($15,000.00) for damages, together with the costs of this action, and for such other and further relief as is deemed just and proper.

Respectfully submitted,

POSNER & CORD, LLC

__________________________
John J. Cord
Counsel for Plaintiff