Jeanette Amos

STATES OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF OAKLAND

JEANNENE R. ALLEN Plaintiff

Case No._____________________NI Judge Joe Brown

V.

JOHN I. PATE, Defendant, _________________________________________________/

Attorney Jeanette Amos P 47420 Amos & Associates Attorney for Plaintiff 20267 Fairport Detroit, Michigan 48205 (313)414-3653

_________________________________________________/

Jeanette Amos

COMPLAINT FOR PERSONAL INJURY

Now comes the Plaintiff Jeannene R Allen through her attorney Jeanette Amos and for her complaint against defendant states,

1. 2.

The plaintiff is a resident of the city of Commerce county of Oakland, state of Michigan. The defendant is a resident of the city of Commerce county of Oakland, state of Michigan.

3.

The acts and occurrences complained of herein took place in Oakland county state of Michigan.

4.

The jurisdiction of this case based on the amount in controversy of the law suit exceeds Twenty- Five Thousands ($25,000) dollars, exclusive of costs, interest and attorney fees.

5.

On April 29, 2004, at approximately 10:00 P.M., plaintiff Jeannene R. Allen (Allen) was driving a vehicle north on Fisher rd towards the intersection Glengary rd in Commerce Michigan.

6.

That at the aforementioned time and place defendant John I Pate (Pate) was driving a vehicle towards the same intersection going south bound in the township of commerce; county of Oakland, state of michigan.

7.

That at the aforementioned time and place the defendant, John Pate caused his motor vehicle to suddenly and violently collide with the vehicle of the plaintiff, Jeannene.

Jeanette Amos

8.

That at the aforesaid time and place, the defendant owed a duty to the plaintiff to use care and caution in the operation and control of his vehicle and he was required to drive with care and circumspection according to Michigan state statutes.

9.

Contrary to said duties owed the defendant John Pete was negligent in the following manners

A. B. C. D. 10.

Drove after drinking with senses impaired. Drove in a careless, headless manner so as endanger Plaintiff. Failed to keep said automobile constantly under control. Willfully and cautionly failed the duties imposed by law. That said negligence and/ or gross negligence by the defendant, John Pate. was/ were the direct and proximate causing of the injuries sustained by the Plaintiff herein.

11.

That the Plaintiff Jeannene Allen as a result of the carelessness, negligence and/ or gross neligences of the defendant, John Pate directly and proximatly substained injuriues resulting in a serious impairment of body fuction and/ or permanent serious disfigurement, and further suffered great and severe physical and mental injuries resulting in her disabilitys, to wit head and body.

12.

As a result of injuries suffered by the Plaintiff proximantly caused by defendant, plaintiff has suffered the following damages .

A. B.

Expenses relative to her medical treatment and will incur cost in future. Loss of imcome and disability and will suffer disability and will suffer disability and lost income in the future.

C. D.

Physical and mental pain and suffering, which will continue in the future. Disfiguration and humiliation, which will continue in future.

Jeanette Amos

E. F.

A psychiatric and mental disability, which will continue in the future. Required attendant care, and will require attendant care in the future.

WHEREFORE, Plaintiff respectfully requests that this court enter judgment in its favor and against Defendant Pate exceeding the amount of twenty-five thousand 00/100 ($25,000.00) Dollars, together with cost and interest, And any other relief this Court deems appropriate under the facts and proofs presented in this matter.

By: __________________________________ Attorney Jeanette Amos P 47420 Amos & Associates Attorney for Plaintiff 20267 Fairport Detroit, Michigan 48205 (313)414-3653

Dated: _____3/12/2011

Plaintiff request a trial by jury

Jeanette Amos

Now comes the Plaintiff Jeannene R Allen through her attorney Jeanette Amos and hereby demands a trial by jury.

Respectfully Submitted,

By: __________________________________ Attorney Jeanette Amos Amos & Associates Attorney for Plaintiff Jeannene Allen Dated: _____3/12/2011 20267 Fairport Detroit, Michigan 48205 P 47420