COMPLAINT

AND NOW comes David M. Thompson, , by his counsel, Karreara Jackson of HACC Law firm, and states against Defendants, Stephen Blanca and Gayle Stuart Trucking, as follows: 1. The plaintiff, David M. Thompson, is an individual residing at 9873 Mulberry Lane in the city of Harrisburg, county of Dauphin, Pennsylvania. 2. The plaintiff’s parent and legal guardian is Albert Thompson, individual residing at 9873 mulberry Lane in the city of Harrisburg, Dauphin County of, Pennsylvania. 3. The defendant, Gayle Stuart Trucking hereafter GST, is a corporation organized and existing under the law of the Commonwealth of Pennsylvania, having its principal place of business at 400 Industrial Road, in the city of Harrisburg, Dauphin County of, Pennsylvania.
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Plaintiff incorporates and realleges by reference herein Paragraphs One through 19 above.
21. State the negligence elements as they apply to this case- use as many paragraphs as necessary
22. Defendant Blanca owed Plaintiff numerous duties including the following:
A .to obey traffic signs.
B. Blanca had the duty to obey the speed limit
C. Blanca had the duty to not hit other vehicles.
23. Defendant Blanca’s breached his duties by the following:
A. Failed by not following proper precautions as a driver.
B. Failing by not obeying traffic laws, signs, and speeds he breached his duty as a driver.
C. Failing to pay attention Blanca initiated the cause of the accident.
24. As a result of Defendant Blanca’s breach Plaintiff has permanent injuries as damages from this accident.:
A. Multiple Spinal fractures
B. A fractured right arm
C. Fractured right leg
D. Spleen removal making plaintiff more susceptible to infections
E. Closed head injury and trauma Plaintiff suffers from short -term memory issues.
F. Plaintiff is unable to participate in following activities since the accident: soccer, baseball, lacrosse, running, walking, and general movement and