Complaint damages filing in Marion County Superior Court

Complaint

LARA LAWYER, ATTORNEY

Lawyer, Attorney, and Counsel, LLC

123 Main Street

Chicago, IL

Phone Number (with area code)

SUPERIOR COURT OF THE STATE OF ILLINOIS

FOR THE COUNTY OF MARION

PRUDENCE SMITH,

Plaintiff,

SHERI MILLER,

Defendant

Case No.: 12-3-456789-1

COMPLAINT FOR DAMAGES

Mrs. Prudence Smith was driving on Banta Road where it intersects Bluff Road in Marion County, Indiana about 7:50 A.M., on January 21, 2011. It was a frosty morning, just prior to sunrise. Mrs. Smith was driving a 1997 Chevrolet Cavalier with burned out tail lights. The brake lights were working inside the vehicle.

Sheri Miller was running late for work on the morning of January 21, 2011 and was traveling behind Mrs. Smith. Mrs. Miller was driving a 2004 Ford F250 pickup truck and her windows were frosted over from being parked outside overnight. She had scraped a small area of her windshield clean.

A deer darted across the road in front of Mrs. Smith's car, just before the intersection of Bluff and Banta, and Mrs. Smith had to slam on her brakes to avoid hitting the deer. Mrs. Miller did not see Mrs. Smith's brake lights in time and collided with the rear end of Mrs. Smith's car.

Mrs. Smith was self-employed as an accountant prior to the accident. Mrs. Smith sustained severe damage to her right hand and right arm, which has resulted in her inability to use her adding machine or computer since the accident. Although her medical treatment is ongoing, it is unknown at this time whether she will ever regain full use of her right arm.

Count 1 -- Accident was caused by the fact that Sheri Miller was following too close and was unable to see due to her windows being frosted over.

Mrs. Smith is suing for damages to pay her current and future medical bills, and relief from her mental distress due to her inability to work. She is also suing for lost wages.

DATED: July 27, 2011

Your signature

In Pro-Per

SUMMONS

In the Marion Circuit Court

Division 5,

Room W507

PRUDENCE SMITH,

Plaintiff

SHERI MILLER,

Defendant

Cause No. 12-3-456789-1

To the Defendant

SHERI MILLER

999 Banta Road

Chicago, IL

You have been Sued by the person(s) named Plaintiff in the court stated above.

The nature of the suit against you is stated in the Complaint which is attached to this Summons.

You must answer the Complaint in writing, by you or your attorney, within twenty (20) days (or within twenty-three (23) days, if this was received by mail), beginning the day after you receive this Summons, or judgment will be entered against you for what the Plaintiff has demanded.

If you have a defense or claim for relief against the Plaintiff arising from the same transaction or incident, you must assert it in your written answer.

If you need the name of an attorney, you may contact the Indianapolis Bar Association Lawyer. Referral Service (269-2222) or the Marion County Bar Association Lawyer Referral Service (634-3950).

STATE OF ILLINOIS SECOND JUDICIAL DISTRICT

COUNTY OF MARION COURT FILE NO.

COMPLAINT FOR DAMAGES

Prudence Smith

PLAINTIFF DEFENDANT'S ANSWER

VS. TO

Sheri Miller PLAINTIFF'S COMPLAINT

DEFENDANT

The Defendant states the following as his/her Answer to Plaintiff's complaint:

On the morning of January 21, 2011, Sheri Miller was traveling behind Prudence Smith on Banta

Road at approximately 7:50 A.M., just prior to sunrise. A deer darted across the road in front of Mrs. Smith's car, just before the intersection of Bluff and Banta Road and Mrs. Smith slammed

On her brakes, to avoid hitting the deer. However, her brake lights were out and it was

Impossible for Mrs. Miller to avoid hitting Mrs. Smith's car since she did not see her brakes.

Defendant asks the Court to dismiss the charges.

Dated: July 27, 2011 Mrs. Sheri Miller

Defendant

999 N. Banta Road

Address

Chicago, IL

City/State/Zip

Telephone

VERIFICATION AND ACKNOWLEDGEMENT

a. I have read this document. To the best of my knowledge, information and belief the information, contained in the document is well grounded in fact and is warranted by existing law.