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STATE OF COLUMBIA
CAPITOL COUNTY
ANN FORRESTER,
Plaintiff,
v.
RICHARD HART and
MERCURY PARCEL SERVICE, INC.,
Defendants,
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COMPLAINT
(Negligence and Loss of Consortium)
The Plaintiff, complaining of the Defendant herein, would show and allege unto this
Honorable Court as follows:
1. Plaintiff is a citizen and resident of the State of Columbia, County of Capital.
2. The defendant Richard Hart is, upon information and belief, a driver for Mercury Parcel service Inc.,
licensed to deliver goods in the State of Columbia.
3. The Defendant Mercury Parcel Service Inc., is a limited liability company organized and doing
business in one of the states of the United States of America and does business in Capital County
Columbia.
4. The court has jurisdiction over the parties and subject matter over this litigation to conduct jury
trial pursuant to the Columbia Rules 193.(b) among the parties.
5. At all times herein, Defendant Richard Hart was acting as the agent, servant, and employee of
Mercury Parcel Service Inc., in distribution concerning the delivery of goods and contracted
through expressed and implied authority.
6. On or about February 26, 20--, Ann Forrester was going to her mailbox and putting a letter in the
mailbox when the Defendant Richard Hart saw miss Forrester and applied his brakes on the icy
DeAnna Douglas
Week 4 Assignment 4.1
LGA4000XA
2 hour 46 minutes
road way. Mr. Hart then stuck Mrs. Forrester and then hit a tree. The Plaintiff is seeking relief for
$75,000 in damages plus hospital bills totaling $45,000.
DeAnna Douglas
Week 4 Assignment 4.1
LGA4000XA
2 hour 46 minutes
17. Plaintiff is seeking relief for the damages due to the incident involving the Plaintiff and Mercury
Parcel Service Inc., in the amount of $75,000 in damages and $45,000 in medical bills as well as
attorneys fees.
18. Plaintiff alleges that Mercury Parcel Service Inc., is also responsible for the damages the plaintiff
endured do to failure to maintain the van driven by the Defendant.
WHEREFORE, having fully pled this Complaint, the Plaintiff prays for relief requested herein and
for such other future relief as this court may deem just and proper.
Arthur White
White, Wilson & McDuff
Attorneys at Law
Federal Plaza Building
Suite 700
Third and Market Streets
Legalville, Columbia 00000
(111) 555-0000
DeAnna Douglas
Week 4 Assignment 4.1
LGA4000XA
2 hour 46 minutes
STATE OF COLUMBIA
CAPITOL COUNTY
ANN FORRESTER,
Plaintiff,
v.
RICHARD HART and
MERCURY PARCEL SERVICE, INC.,
Defendants,
Notice
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