STATE OF COLUMBIA CAPITOL COUNTY CIRCUIT COURT

ANN FORRESTER and

WILLIAM FORRESTER, Plaintiffs

v. Civil Action, File No. 1000

RICHARD HART and

MERCURY PARCEL SERVICE, INC., Defendants JURY TRIAL DEMANDED

COUNT I

1. Plaintiffs are citizens of the State of Columbia and Defendant Hart is a citizen of the State of Ohio; Defendant Mercury Parcel Service, Inc., is a corporation incorporated under the laws of the State of Delaware, having its principal place of business in the State of Ohio. The matter in controversy exceeds, exclusive of interest and costs, the sum of $75,000.

2. On February 26, 2015, on Highway 328 in Capitol County, Columbia, Defendant Hart, an employee of Defendant Mercury Parcel, Inc., negligently drove a motor vehicle striking down Plaintiff who was crossing said highway.

3. As a result, Plaintiff fractured her left leg and hip bones and was otherwise seriously injured; has been prevented from transacting her business; has suffered, and continues to suffer, great pain of body and mind; has incurred, and will continue to incur, expenses for medical attention and hospitalization, all to the sum of $750,000.

WHEREFORE Plaintiff demands judgment against Defendant in the sum of $750,000.

COUNT II

4. Plaintiff William Forrester hereby alleges and incorporates by reference paragraphs 1 through 3 of Count One.

5. Because of Defendant’s negligence, Plaintiff has suffered loss of the consortium of his wife, Ann Forrester, in the amount of $20,000.

WHEREFORE, Plaintiff demands judgment against the Defendant in the sum of $20,000.

____________________________Braydon Kopejtka

White, Wilson, & McDuffAttorneys at Law

Federal Plaza BuildingSuite 700

Third and Market StreetsLegalville, Columbia 00000