Automobile Accident Complaint 4 (head-on collision)

Download PDF Version



Complaint at Law

Lindner, Speers & Reuland, P.C., By: George P. Lindner (01667491), Attorney for Administrator, 54 West Downer Place, P.O. Box 5055, Aurora, Illinois 60507-5055, 630/892-8109.

NOW COMES plaintiff and by Lindner, Speers & Reuland, P.C., as attorneys, and for his complaint against defendant Gina Terpstra states as follows:

1. That an automobile collision between an automobile being driven by Gina Terpstra and plaintiffs decedent occurred on October 29, 2003, 5:25 p.m. in the 700 block of Pine Street in the unincorporated area of the City of Batavia, Kane County, Illinois.

2. That at all times material defendant was operating a vehicle in a westerly direction on Pine Street and that plaintiff's decedent was walking from the south side of Pine street to the north side after having picked up her mail.

3. That defendant had a duty not to injure plaintiff but wholly notwithstanding that duty she negligently committed one or more of the following acts or omissions:

a. Failed to keep a proper look out.

b. Failed to drive her vehicle at a speed which was reasonable and proper considering the traffic, pedestrian traffic, and the conditions of the highway.

4. That as a direct and proximate result of defendant's negligence a collision occurred injuring Peggy Haines which said injuries ultimately resulted in the death of plaintiff's decedent.

5. The plaintiff's decedent left surviving, at the time of her death, four next of kin those next of kin being a son David Haines, and three daughters, Laura Mears, Karen Zellmer, and Sharon Haines, all of whom were dependant upon the decedent for socrety, companionship, guidance, instruction, and motherly support.

6. That as a direct and proximate result of defendant's negligence in the collision, injuries, and death which occurred, described above, plaintiff's next of kin has suffered damages compensable by Illinois law.

7. That David Haines is the administrator of the Estate of Peggy Haines.

WHEREFORE plaintiff prays for judgment against defendant in a sum in excess of FIFTY THOUSDAND DOLLARS ($50,000.00).

DATED this 4th day of November, 2003.

LINDNER, SPEERS & REULAND, P.C.

BY: George P. Lindner (01667491)

Attorney for Administrator

54 West Downer Place

P.O. Box 5055

Aurora, Illinois 60507-5055

630/892-8109

Client Reviews
Jonathan Rosenfeld was professionally objective, timely, and knowledgeable. Also, his advice was extremely effective regarding my case. In addition, Jonathan was understanding and patient pertaining to any of my questions or concerns. I was very happy with the end result and I highly recommend Jonathan Rosenfeld.
★★★★★
Extremely impressed with this law firm. They took control of a bad motorcycle crash that left my uncle seriously injured. Without any guarantee of a financial recovery, they went out and hired accident investigators and engineers to help prove how the accident happened. I am grateful that they worked on a contingency fee basis as there was no way we could have paid for these services on our own. Ethan Armstrong, Google User
★★★★★
This lawyer really helped me get compensation for my motorcycle accident case. I know there is no way that I could have gotten anywhere near the amount that Mr. Rosenfeld was able to get to settle my case. Thank you. Daniel Kaim, Avvo User
★★★★★
Jonathan helped my family heal and get compensation after our child was suffered a life threatening injury at daycare. He was sympathetic and in constant contact with us letting us know all he knew every step of the way. We were so blessed to find Jonathan! Giulia, Avvo User
★★★★★
Jonathan did a great job helping my family navigate through a lengthy lawsuit involving my grandmother's death in a nursing home. Through every step of the case, Jonathan kept my family informed of the progression of the case. Although our case eventually settled at a mediation, I really was impressed at how well prepared Jonathan was to take the case to trial. Lisa, Avvo User
★★★★★
Contact Us for a Free Consultation (888) 424-5757
Chicago Office Map