News-Herald, IN THE COURT OF COMMON PLEAS, LAKE COUNTY, OHIO EDGAR AZNAUROV, 7262 Sherman Road, Chesterland, Ohio 44026 Plaintiff vs. ADAM DAVIS, Address unknown Defendant COMPLAINT WITH JURY DEMAND Case No.: 14CV001929 • Judge: Eugene Lucci Now comes the Plaintiff, EDGAR AZNAUROV, by and through the undersigned attorney, and hereby states his Complaint against the Defendant, ADAM DAVIS, as follows: JURISDICTION AND VENUE 1. The accident that is the subject matter of this Complaint occurred at Mentor, Lake County, Ohio making jurisdiction and venue over the parties and subject matter of this Complaint proper in this court. COUNT ONE: NEGLIGENCE 2. The Plaintiff hereby incorporates all of the allegations, statements and averments contained in paragraph one of her Complaint as if fully rewritten herein. 3. The Plaintiff states that on October 5, 2012, he was operating a motor vehicle on Salida Road, located in Mentor, Lake County, Ohio. 4. On the same date and time, the Defendant was operating a vehicle behind the Plaintiff. 5. The Plaintiff states that he slowed down to allow a cat to cross the street and the Defendant struck the rear end of his vehicle. 6. The Defendant owed a duty to the Plaintiff to safely operate his motor vehicle. 7. The Defendant breached his duty when he negligently operated his motor vehicle and caused it to collide into the Plaintiff. 8. As a direct and proximate cause of the Defendant’s negligent operation of a motor vehicle, the Plaintiff suffered serious physical injuries including, but not limited to, cervical sprain/strain; thoracic sprain/strain; lumbar sprain/strain; left/right knee sprain/strain; sprain of elbow; lumbosacral joint/ligament sprain; post-concussive syndrome; disc herniation at C4/5; lumbosacral myofascitis; left C5/6 radiculopathy; torn left lateral meniscus; and right meniscal contusion; incurred significant medical expenses, which will be more clearly set forth at trial, and expects to incur additional medical expenses in the future to treat his injuries; and incurred mental anguish, emotional distress, past and future physical pain and suffering, and the loss of enjoyment of life. WHEREFORE, the Plaintiff, EDGAR AZNAUROV, demands judgment against the Defendant, ADAM DAVIS, in an amount in excess of Twenty Five Thousand and 00/00s Dollars ($25,000.00), the exact amount which will be proven at trial, along with costs, reasonable attorneys fees, statutory interest from the date of judgment and any additional relief which this Court finds just and equitable. Carly A. Ibold (#0080010) Petersen & Ibold, Counsel for the Plaintiff 401 South Street, Chardon, Ohio 44024 Phone: (440) 285-3511 ext. 214 • Fax: (440) 285-3363 carly@peteribold.com • 635748/June 6, 13 and 20, 2015
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