Litigation Complaint , law homework help

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COMPLAINT
ASSIGNMENT

Read
the attached fact situation.  Ms. Stella
King  comes to your law firm, Jones &
Jones, P.C., to request that your firm file a lawsuit against Donald Woods.  Your supervising attorney asks you to draft a
complaint in the matter of King v. Woods based on automobile negligence.  Ms. King lives in Bloomfield Hills, MI.  Donald Woods is a resident of Plymouth Township,
Michigan.  You are to ask for a jury
trial.

Please
rely primarily on the facts as they appear in the Factual Statement.  You may make up such things as names of
attorneys, addresses, etc.  Your
complaint must be typed and submitted via Blackboard.

This assignment is due October 18, 2016

  FACTUAL STATEMENT

On
January 5, 2016, Stella King was driving her 2016 Explorer on Main Street south
of Eight Mile in the Township of Northville, the County of Wayne.  She was traveling southbound in the left lane
of traffic.  Just as she passed the Coney
Island, the right lane ended and the traffic from that lane was to merge with
the left lane. (Stella’s lane) Just as Stella was approaching the spot where
the lanes merged, Donald Woods, driving a 2014 Jaguar XJ, pulled in front of
her without warning, hit her vehicle on the front side and caused her to lose
control of her vehicle and drive off the road. 
Donald Woods was ticketed for careless driving, exceeding the speed
limit, and failure to use his turn signal. 

Ms.
King was taken to the hospital where she suffered a concussion, a broken arm,
and collar bone, as well as numerous internal injuries, contusions and
bruises.  She was kept in the hospital
for one week and could not return to her job as a real estate broker for 2
months.  Her doctors are uncertain if she
will ever have the complete use of her right arm again as it still continues to
be very painful.  So far her medical
bills exceed $50,000.00, and her very lucrative career (she reported over
$200,000.00 per year t
o the IRS) is in jeopardy.

The Elements of the Cause of Action For Auto
Negligence:

1. A person operating a motor vehicle has
a legal duty to exercise ordinary and reasonable care while operating
the vehicle on a road, highway, or a place open to the public;

2. If a person breaches the duty;
and

3. damages result; and

4. the breach of the duty is the proximate
cause of the damages
then that person may be liable for personal injury
auto negligence.

Will provide a sample if needed.

Must be suffiecient and correct!

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