Manchester NH Pedestrian Motor Vehicle Accident
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MERRIMACK COUNTY SUPERIOR COURT, CONCORD NH
1. The Plaintiff is an individual residing in City of Concord, State of New Hampshire 03301 and was at all relevant times hereto lawfully married.
2. The Plaintiff husband is an individual residing in City of Concord, State of New Hampshire 03301.
3. The Defendant is an individual and on information and belief a resident of Town of Pembroke, State of New Hampshire 03275 and was at all relevant times hereto, the operator of motor vehicle traveling on Manchester Street, a public right of way within the city of Concord, New Hampshire.
COUNT I (Negligence)
4. On or about December 29, 2008 the Defendant operated his motor vehicle so as to strike the plaintiff, a pedestrian, while she was in the process of crossing Manchester Street.
5. At all times relevant hereto the Defendant owed a duty to the Plaintiff to use reasonable care in the operation of his vehicle under the circumstances then and there existing.
6. The Defendant breached the duty of care as owed to the Plaintiff by failing to operate the subject vehicle with reasonable care, by failing to keep a proper lookout, by failing to yield the right of way and by operating said vehicle so as to strike the Plaintiff.
7. That as a direct and proximate result of the negligence of the Defendant, as herein alleged, the Plaintiff was caused to sustain severe physical injuries and conscious pain and suffering.
8. That as a direct and proximate result of the negligence of the Defendant as herein alleged, the Plaintiff has been caused to incur medical expenses for treatment of injuries sustained and is likely to incur future medical expenses.
9. That as a direct and proximate result of the negligence of the Defendant as herein alleged, the Plaintiff has been caused to lose wages.
10. That the Plaintiff bears no fault for the injuries and damages as alleged.
WHEREFORE, Plaintiff requests:
1. Judgment for damages plus interest from the day of her cause of action.
2. Reasonable cost and attorney’s fees.
3. For such other and further relief as this Honorable court may deem just and proper.
The Plaintiff demands a jury hear her cause.
COUNT II (Loss of Consortium)
11. This count on behalf of the plaintiff husband for loss of consortium and incorporates by reference herein paragraphs one through 10 and states further;
12. That on December 29, 2008 husband was lawfully married to injured plaintiff living together as husband and wife.
13. That as a direct and proximate result of the negligence of the Defendant and injuries sustained by his lawful wife, as hereinbefore alleged, husband has been deprived of the love, affection, society, companionship and income of his wife
WHEREFORE, Plaintiff husband requests:
4. Judgment for damages plus interest from the day of his cause of action.
5. Reasonable cost and attorney’s fees.
6. For such other and further relief as this Honorable court may deem just and proper.
The Plaintiff husband demands a jury hear his cause.
