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)
)
Plaintiff, )
) CASE NO. 16C-_______
v. )
) Jury Demand (12)
RANDALL DORAN, )
)
Defendant. )
COMPLAINT
The Parties
Tennessee.
2. Randall Doran (the Defendant) was the driver of the vehicle that hit the
vehicle in which the Plaintiff was operating at the time of the July 29, 2015 car accident
the time of the accident described herein, the Defendant lived at 253 Beulah Church
Preliminary Issues
4. This is a negligence action involving the July 29, 2015 car accident that
involved the parties. This car accident occurred in Davidson County, Tennessee. The
Tennessee.
7. The Defendant was properly served with this lawsuit and the Complaint.
9. On July 29, 2015, the parties were involved in a car accident. The accident
occurred as a result of the Defendant negligently driving the motor vehicle that the
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AUTO ACCIDENT LAWSUIT
Defendant was operating into the vehicle that the Plaintiff was operating. The
Plaintiffs vehicle was properly stopped in traffic when the Defendant drove the
Defendants vehicle into the back of the Plaintiffs vehicle and caused the impact. The
Defendants negligence caused the accident, which resulted in physical injuries and
medical expenses.
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but not limited to, not keeping a careful watch, and not driving carefully.
12. As a matter of law, the Defendant violated Tenn. Code Ann. section 55-8-
136(b) by failing to operate a motor vehicle with due care, by not keeping a safe
lookout, and by not devoting full time and attention to operating a motor vehicle, all of
which, in part or in combination, caused the car accident. The Defendants violations
of these statutory provisions constitute negligence per se, to which the Defendant is
liable to the Plaintiff for all resulting injuries and damages the Plaintiff sustained,
because the Plaintiff is a member of the class of persons who these statutes exists to
protect.
13. The Plaintiff suffered injuries as a result of the accident, including physical
pain and suffering. These injuries included, but are not limited to, (1) a concussion
and (2) post-concussion headaches and light sensitivity. The Plaintiff has received
medical care for the injuries from the collision. The Plaintiff will have future physical
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14. As a result of the care and treatment provided in response to the car
accident, the Plaintiff incurred medical expenses, all of which were reasonable and
necessary in amount, and which were caused by the car accident. These medical
bills are attached, and the documented charges are presumed to be necessary and
15. As a result of the care and treatment provided in response to the car
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accident, the Plaintiff lost income related to not being able to close on sales at the
end of July 2015 that he otherwise would have closed. Those lost sales caused the
Plaintiff to lose some income that would have been earned via commissions, and
caused the Plaintiff to lose some income that would have been earned for bonus /
incentive pay for sales closed by the end of July 2015 that were not closed during that
timeframe.
16. The Defendants negligence caused the car accident. The Defendants
negligence was the actual cause and proximate cause of the injuries and damages
to the Plaintiff. The Defendant is liable to the Plaintiff for the Plaintiffs injuries and
damages.
1. That service of process issue for the Defendant at the address listed above,
2. That the Plaintiff recover from the Defendant all of the following items:
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E. Any other relief which the Court determines to be just and proper.
Cummings Manookian 45 Music Square West, Nashville, Tennessee 37203
WHEREFORE, the Plaintiff sues the Defendant for the damages outlined above,
pursuant to the terms of the facts, the claims, and Tennessee law.
Respectfully submitted,
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Cummings Manookian 45 Music Square West, Nashville, Tennessee 37203
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Respectfully submitted,
(T) 615-266-3333
(F) 615-266-0250
Cummings Manookian 45 Music Square West, Nashville, Tennessee 37203
bcummings@cummingsmanookian.com
bmanookian@cummingsmanookian.com
www.cmtrialattorneys.com
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