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Virginia Negligence Complaint Clarification
Summary
The complaint involves a motor vehicle collision in Virginia, where the First Defendant, Hunter Lee Scarce, was operating a delivery truck owned by United Parcel Service, Inc. The court has jurisdiction under Virginia Code § 8.01-328.1 due to the defendants residency and the incidents location. Venue is proper under Virginia Code §§ 8.01-261 and 8.01-262. The Plaintiff, Dana Marie Snider, was driving lawfully when the First Defendant crossed into her lane, causing a collision. The Plaintiff sustained injuries and continues to receive medical treatment. The negligence claim against the First Defendant includes failure to operate the vehicle safely and within traffic laws while acting within the scope of employment.Full Conversation
Rewrite this part of my complaint filing in Patrick County Circuit Court in Virginia making it sound less Confusing: JURISDICTION AND VENUE
This Court has jurisdiction over this matter pursuant to Virginia Code § *.*-*.*, as the First Defendant is a resident of Virginia and the cause of action arises from a motor vehicle collision occurring in the state.
This Court is the proper venue for this matter pursuant to Virginia Code § *.*-*, as the Second Defendant regularly or systematically conducts affairs or business activity in Patrick County, Virginia, and pursuant to Virginia Code § *.*-*, as the motor vehicle accident occurred in Patrick County, Virginia.
Sure, ****, here's a simplified version of your "Jurisdiction and Venue" section:
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JURISDICTION AND VENUE
This Court has jurisdiction under Virginia Code § *.*-*.* because the First Defendant resides in Virginia, and the motor vehicle collision occurred in the state.
This Court is the proper venue under Virginia Code § *.*-* because the Second Defendant conducts business in Patrick County, Virginia, and under Virginia Code § *.*-* because the accident occurred in Patrick County.
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JURISDICTION AND VENUE
This Court has jurisdiction under Virginia Code § *.*-*.* because the First Defendant resides in Virginia, and the motor vehicle collision occurred in the state.
This Court is the proper venue under Virginia Code § *.*-* because the Second Defendant conducts business in Patrick County, Virginia, and under Virginia Code § *.*-* because the accident occurred in Patrick County.
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I hope this helps! Is there anything else you need clarification on?
is the citing for laws correct?
The citing for the laws appears to be correct, but you should always double-check with the latest legal texts to ensure accuracy. Here are the main points:
- Virginia Code § *.*-*.*: Jurisdiction based on the defendant's residency and the cause of action arising in Virginia.
- Virginia Code § *.*-*: Venue based on the defendant's business conduct.
- Virginia Code § *.*-*: Venue based on where the accident occurred.
Do you need help with anything else related to your filing?
- Virginia Code § *.*-*.*: Jurisdiction based on the defendant's residency and the cause of action arising in Virginia.
- Virginia Code § *.*-*: Venue based on the defendant's business conduct.
- Virginia Code § *.*-*: Venue based on where the accident occurred.
Do you need help with anything else related to your filing?
Rewrite the Facts to my complaint making it sound more clear and precise: FACTS
The incident occurred on Dangler Mountain Road in Stuart, Virginia, approximately *.* miles from Collinstown Road in Stuart, Virginia, on October *, *, at approximately *:* PM.
The Plaintiff, **** Marie Snider, was operating a * Chevrolet Cobalt.
The First Defendant, Hunter Lee Scarce, was operating a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
The Plaintiff was traveling toward Collinstown Road, when the First Defendant traveling in the opposite direction, crossed over into the Plaintiff's lane, and struck the front of the Plaintiff's vehicle at an angle.
FACTS
- On October *, *, at approximately *:* PM, an incident occurred on Dangler Mountain Road in Stuart, Virginia, about *.* miles from Collinstown Road.
- Plaintiff, **** Marie Snider, was driving a * Chevrolet Cobalt.
- First Defendant, Hunter Lee Scarce, was driving a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
- Plaintiff was traveling towards Collinstown Road when the First Defendant, traveling in the opposite direction, crossed into Plaintiff's lane and struck the front of her vehicle.
- At the time, Plaintiff was traveling at * mph, and the First Defendant at * mph.
- Plaintiff was driving lawfully in her lane and was not negligent in any way.
- As a result of the collision, Plaintiff sustained injuries, including a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
- Plaintiff was transported by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina.
- Plaintiff is still receiving ongoing medical treatment for her injuries.
Would you like anyWould you like any additional information or assistance with another part of your complaint?
- On October *, *, at approximately *:* PM, an incident occurred on Dangler Mountain Road in Stuart, Virginia, about *.* miles from Collinstown Road.
- Plaintiff, **** Marie Snider, was driving a * Chevrolet Cobalt.
- First Defendant, Hunter Lee Scarce, was driving a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
- Plaintiff was traveling towards Collinstown Road when the First Defendant, traveling in the opposite direction, crossed into Plaintiff's lane and struck the front of her vehicle.
- At the time, Plaintiff was traveling at * mph, and the First Defendant at * mph.
- Plaintiff was driving lawfully in her lane and was not negligent in any way.
- As a result of the collision, Plaintiff sustained injuries, including a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
- Plaintiff was transported by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina.
- Plaintiff is still receiving ongoing medical treatment for her injuries.
Would you like anyWould you like any additional information or assistance with another part of your complaint?
rewrite this statement of facts
Sure, here's a more concise and clear version of your "Facts" section:
FACTS
- On October *, *, at approximately *:* PM, an incident occurred on Dangler Mountain Road in Stuart, Virginia, about *.* miles from Collinstown Road.
- Plaintiff, **** Marie Snider, was driving a * Chevrolet Cobalt.
- First Defendant, Hunter Lee Scarce, was driving a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
- Plaintiff was traveling towards Collinstown Road when the First Defendant, traveling in the opposite direction, crossed into Plaintiff's lane and struck the front of her vehicle.
- At the time, Plaintiff was traveling at * mph, and the First Defendant at * mph.
- Plaintiff was driving lawfully and was not negligent in any way.
- As a result of the collision, Plaintiff sustained injuries including a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
- Plaintiff was transported by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina.
- Plaintiff is stillreceiving ongoing medical treatment for her injuries.
Would you like any additional information or assistance with another part of your complaint?
- On October *, *, at approximately *:* PM, an incident occurred on Dangler Mountain Road in Stuart, Virginia, about *.* miles from Collinstown Road.
- Plaintiff, **** Marie Snider, was driving a * Chevrolet Cobalt.
- First Defendant, Hunter Lee Scarce, was driving a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
- Plaintiff was traveling towards Collinstown Road when the First Defendant, traveling in the opposite direction, crossed into Plaintiff's lane and struck the front of her vehicle.
- At the time, Plaintiff was traveling at * mph, and the First Defendant at * mph.
- Plaintiff was driving lawfully and was not negligent in any way.
- As a result of the collision, Plaintiff sustained injuries including a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
- Plaintiff was transported by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina.
- Plaintiff is stillreceiving ongoing medical treatment for her injuries.
Would you like any additional information or assistance with another part of your complaint?
At the point of impact, At the time, Plaintiff was traveling at * mph, and the First Defendant at * mph.
Sure, ****! Here's a more clear and precise rewrite of your statement of facts:
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FACTS
- On October *, *, at approximately *:* PM, an incident occurred on Dangler Mountain Road in Stuart, Virginia, about *.* miles from Collinstown Road.
- Plaintiff, **** Marie Snider, was driving a * Chevrolet Cobalt.
- First Defendant, Hunter Lee Scarce, was driving a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
- Plaintiff was traveling towards Collinstown Road when the First Defendant, traveling in the opposite direction, crossed into Plaintiff's lane and struck the front of her vehicle at an angle.
- At the time of impact, the Plaintiff was traveling at * mph and the First Defendant at * mph.
- Plaintiff was driving lawfully in her lane and was not negligent in any way.
- As a result of the collision, Plaintiff sustained injuries, including a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
- Plaintiff was transported by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina.
- Plaintiff is still receiving ongoing medical treatment for her injuries.
---
Is there anything else you need help with in your complaint?
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FACTS
- On October *, *, at approximately *:* PM, an incident occurred on Dangler Mountain Road in Stuart, Virginia, about *.* miles from Collinstown Road.
- Plaintiff, **** Marie Snider, was driving a * Chevrolet Cobalt.
- First Defendant, Hunter Lee Scarce, was driving a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
- Plaintiff was traveling towards Collinstown Road when the First Defendant, traveling in the opposite direction, crossed into Plaintiff's lane and struck the front of her vehicle at an angle.
- At the time of impact, the Plaintiff was traveling at * mph and the First Defendant at * mph.
- Plaintiff was driving lawfully in her lane and was not negligent in any way.
- As a result of the collision, Plaintiff sustained injuries, including a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
- Plaintiff was transported by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina.
- Plaintiff is still receiving ongoing medical treatment for her injuries.
---
Is there anything else you need help with in your complaint?
Rewrite this statement of facts:
Sure, ****! Here's a clearer and more concise version of your statement of facts:
---
FACTS
- On October *, *, at approximately *:* PM, an incident occurred on Dangler Mountain Road in Stuart, Virginia, about *.* miles from Collinstown Road.
- Plaintiff, **** Marie Snider, was driving a * Chevrolet Cobalt.
- First Defendant, Hunter Lee Scarce, was driving a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
- Plaintiff was traveling towards Collinstown Road when the First Defendant crossed into Plaintiff's lane and struck her vehicle at an angle.
- At the time of impact, Plaintiff was traveling at * mph, and the First Defendant at * mph.
- Plaintiff was driving lawfully and was not negligent.
- As a result of the collision, Plaintiff sustained injuries including a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
- Plaintiff was transported by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina.
- Plaintiff is still receiving ongoing medical treatment for herinjuries.
---
Is there anything else you need help with in your complaint?
---
FACTS
- On October *, *, at approximately *:* PM, an incident occurred on Dangler Mountain Road in Stuart, Virginia, about *.* miles from Collinstown Road.
- Plaintiff, **** Marie Snider, was driving a * Chevrolet Cobalt.
- First Defendant, Hunter Lee Scarce, was driving a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
- Plaintiff was traveling towards Collinstown Road when the First Defendant crossed into Plaintiff's lane and struck her vehicle at an angle.
- At the time of impact, Plaintiff was traveling at * mph, and the First Defendant at * mph.
- Plaintiff was driving lawfully and was not negligent.
- As a result of the collision, Plaintiff sustained injuries including a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
- Plaintiff was transported by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina.
- Plaintiff is still receiving ongoing medical treatment for herinjuries.
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Is there anything else you need help with in your complaint?
Rewrite this: At the time of the incident, the Plaintiff, **** Marie Snider, was operating her vehicle lawfully and prudently, traveling at a safe speed and in her proper lane of travel.
As a direct result of the collision, the Plaintiff sustained injuries, and was transported from the scene of the accident by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina, to receive treatment for a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
The Plaintiff is still receiving ongoing medical treatment to determine the full nature and extent of injuries caused by the incident.
Sure, ****! Here's a clearer and more concise version of your statement:
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At the time of the incident, Plaintiff **** Marie Snider was driving lawfully and prudently at a safe speed in her proper lane. As a direct result of the collision, she sustained injuries and was transported by ambulance to Northern Regional Hospital in Mt. Airy, NC, for treatment of a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder. Plaintiff continues to receive ongoing medical treatment to assess the full extent of her injuries.
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Is there anything else you need assistance with in your complaint?
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At the time of the incident, Plaintiff **** Marie Snider was driving lawfully and prudently at a safe speed in her proper lane. As a direct result of the collision, she sustained injuries and was transported by ambulance to Northern Regional Hospital in Mt. Airy, NC, for treatment of a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder. Plaintiff continues to receive ongoing medical treatment to assess the full extent of her injuries.
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Is there anything else you need assistance with in your complaint?
Rewrite this part of the complaint making it sound more precise and clear
Sure, ****! Here's a more precise and clear version of your statement:
---
FACTS
- On October *, *, at approximately *:* PM, an incident occurred on Dangler Mountain Road in Stuart, Virginia, about *.* miles from Collinstown Road.
- Plaintiff, **** Marie Snider, was driving a * Chevrolet Cobalt.
- First Defendant, Hunter Lee Scarce, was driving a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
- Plaintiff was traveling towards Collinstown Road when the First Defendant crossed into Plaintiff's lane and struck her vehicle at an angle.
- At the time of impact, Plaintiff was traveling at * mph, and the First Defendant at * mph.
- Plaintiff was driving lawfully and prudently in her proper lane.
- As a result of the collision, Plaintiff sustained injuries, including a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
- Plaintiff was transported by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina.
- Plaintiff continues to receive ongoing medical treatmentWould you like any additional information or assistance with another part of your complaint?
---
FACTS
- On October *, *, at approximately *:* PM, an incident occurred on Dangler Mountain Road in Stuart, Virginia, about *.* miles from Collinstown Road.
- Plaintiff, **** Marie Snider, was driving a * Chevrolet Cobalt.
- First Defendant, Hunter Lee Scarce, was driving a * Workhorse W31042 delivery truck owned by the Second Defendant, United Parcel Service, Inc.
- Plaintiff was traveling towards Collinstown Road when the First Defendant crossed into Plaintiff's lane and struck her vehicle at an angle.
- At the time of impact, Plaintiff was traveling at * mph, and the First Defendant at * mph.
- Plaintiff was driving lawfully and prudently in her proper lane.
- As a result of the collision, Plaintiff sustained injuries, including a seatbelt burn, a lateral malleolar fracture to her right ankle, a left lateral cervical strain, and a sprain to her left shoulder.
- Plaintiff was transported by ambulance to Northern Regional Hospital in Mt. Airy, North Carolina.
- Plaintiff continues to receive ongoing medical treatmentWould you like any additional information or assistance with another part of your complaint?
Rewrite this part of the complaint making it sound more precise and clear: COUNT I: NEGLIGENCE
(As to HUNTER LEE SCARCE)
The Plaintiff hereby realleges and incorporates paragraphs one (*) through fourteen (*) as fully set forth herein.
On October *, *, the First Defendant, Hunter Lee Scarce, was in possession, custody, and control of the commercial vehicle owned by the Second Defendant.
At all material times, the First Defendant owed a duty to operate the commercial vehicle with reasonable care to avoid causing harm to other individuals, on the above-described roadways, and in particular, the Plaintiff, as he was careless and negligent in the ownership and operation of the UPS Truck.
Sure, ****! Here's a more precise and clear version of your "COUNT I: NEGLIGENCE" section:
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COUNT I: NEGLIGENCE
*(As to HUNTER LEE SCARCE)*
- The Plaintiff realleges and incorporates paragraphs one (*) through fourteen (*) as fully set forth herein.
- On October *, *, the First Defendant, Hunter Lee Scarce, controlled the commercial vehicle owned by the Second Defendant.
- The First Defendant had a duty to operate the vehicle with reasonable care to avoid harm to others, including the Plaintiff.
- The First Defendant was negligent in:
- Failing to operate the vehicle safely and reasonably.
- Failing to comply with traffic laws.
- Failing to maintain a proper lookout.
- Failing to stay within his lane.
- Failing to consider the safety of other road users.
- Failing to avoid the collision with the Plaintiff's vehicle.
- Other acts of negligence to be determined through discovery.
- The First Defendant breached his duties, directly causing the Plaintiff's injuries in the collision.
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Is there anything else you need help with in your complaint?
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COUNT I: NEGLIGENCE
*(As to HUNTER LEE SCARCE)*
- The Plaintiff realleges and incorporates paragraphs one (*) through fourteen (*) as fully set forth herein.
- On October *, *, the First Defendant, Hunter Lee Scarce, controlled the commercial vehicle owned by the Second Defendant.
- The First Defendant had a duty to operate the vehicle with reasonable care to avoid harm to others, including the Plaintiff.
- The First Defendant was negligent in:
- Failing to operate the vehicle safely and reasonably.
- Failing to comply with traffic laws.
- Failing to maintain a proper lookout.
- Failing to stay within his lane.
- Failing to consider the safety of other road users.
- Failing to avoid the collision with the Plaintiff's vehicle.
- Other acts of negligence to be determined through discovery.
- The First Defendant breached his duties, directly causing the Plaintiff's injuries in the collision.
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Is there anything else you need help with in your complaint?
add how the first defendent was acting within his scope of employment
Sure, ****! Here's the revised "COUNT I: NEGLIGENCE" section with the addition of how the First Defendant was acting within his scope of employment:
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COUNT I: NEGLIGENCE
*(As to HUNTER LEE SCARCE)*
- The Plaintiff realleges and incorporates paragraphs one (*) through fourteen (*) as fully set forth herein.
- On October *, *, the First Defendant, Hunter Lee Scarce, controlled the commercial vehicle owned by the Second Defendant.
- At all material times, the First Defendant was acting within the scope of his employment with the Second Defendant, United Parcel Service, Inc.
- The First Defendant had a duty to operate the vehicle with reasonable care to avoid harm to others, including the Plaintiff.
- The First Defendant was negligent in:
- Failing to operate the vehicle safely and reasonably.
- Failing to comply with traffic laws.
- Failing to maintain a proper lookout.
- Failing to stay within his lane.
- Failing to consider the safety of other road users.
- Failing to avoid the collision with the Plaintiff's vehicle.
- Other acts of negligence to be determined through discovery.
- The First Defendant breached hisduties, directly causing the Plaintiff's injuries in the collision.
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Is there anything else you need assistance with in your complaint?
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COUNT I: NEGLIGENCE
*(As to HUNTER LEE SCARCE)*
- The Plaintiff realleges and incorporates paragraphs one (*) through fourteen (*) as fully set forth herein.
- On October *, *, the First Defendant, Hunter Lee Scarce, controlled the commercial vehicle owned by the Second Defendant.
- At all material times, the First Defendant was acting within the scope of his employment with the Second Defendant, United Parcel Service, Inc.
- The First Defendant had a duty to operate the vehicle with reasonable care to avoid harm to others, including the Plaintiff.
- The First Defendant was negligent in:
- Failing to operate the vehicle safely and reasonably.
- Failing to comply with traffic laws.
- Failing to maintain a proper lookout.
- Failing to stay within his lane.
- Failing to consider the safety of other road users.
- Failing to avoid the collision with the Plaintiff's vehicle.
- Other acts of negligence to be determined through discovery.
- The First Defendant breached hisduties, directly causing the Plaintiff's injuries in the collision.
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Is there anything else you need assistance with in your complaint?
Rewrite to make it sound more clear: COUNT I: NEGLIGENCE
(As to HUNTER LEE SCARCE)
The Plaintiff hereby realleges and incorporates paragraphs one (*) through fourteen (*) as fully set forth herein.
On October *, *, the First Defendant, Hunter Lee Scarce, was in possession, custody, and control of the commercial vehicle owned by the Second Defendant, while acting within the scope of his employment.
At all material times, the First Defendant owed a duty to operate the commercial vehicle with reasonable care to avoid causing harm to other individuals, on the above-described roadways, and in particular, the Plaintiff, as he was careless and negligent in the ownership and operation of the UPS Truck.
Sure, ****! Here's a clearer and more concise version of your "COUNT I: NEGLIGENCE" section:
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COUNT I: NEGLIGENCE
*(As to HUNTER LEE SCARCE)*
- The Plaintiff realleges and incorporates paragraphs one (*) through fourteen (*) as fully set forth herein.
- On October *, *, the First Defendant, Hunter Lee Scarce, was in possession, custody, and control of the commercial vehicle owned by the Second Defendant, while acting within the scope of his employment.
- The First Defendant had a duty to operate the commercial vehicle with reasonable care to avoid causing harm to others, including the Plaintiff.
- The First Defendant was negligent in:
- Failing to operate the vehicle safely and reasonably.
- Failing to comply with traffic laws.
- Failing to maintain a proper lookout.
- Failing to stay within his lane.
- Failing to consider the safety of other road users.
- Failing to avoid the collision with the Plaintiff's vehicle.
- Other acts of negligence to be determined through discovery.
- The First Defendant breached his duties, directly causing the Plaintiff's injuries in the collision.
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Is there anything else youneed help with in your complaint?
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COUNT I: NEGLIGENCE
*(As to HUNTER LEE SCARCE)*
- The Plaintiff realleges and incorporates paragraphs one (*) through fourteen (*) as fully set forth herein.
- On October *, *, the First Defendant, Hunter Lee Scarce, was in possession, custody, and control of the commercial vehicle owned by the Second Defendant, while acting within the scope of his employment.
- The First Defendant had a duty to operate the commercial vehicle with reasonable care to avoid causing harm to others, including the Plaintiff.
- The First Defendant was negligent in:
- Failing to operate the vehicle safely and reasonably.
- Failing to comply with traffic laws.
- Failing to maintain a proper lookout.
- Failing to stay within his lane.
- Failing to consider the safety of other road users.
- Failing to avoid the collision with the Plaintiff's vehicle.
- Other acts of negligence to be determined through discovery.
- The First Defendant breached his duties, directly causing the Plaintiff's injuries in the collision.
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Is there anything else youneed help with in your complaint?
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