ROBERSON v. ADANALIC et al complaint

8/20/2019 ROBERSON v. ADANALIC et al complaint

http://slidepdf.com/reader/full/roberson-v-adanalic-et-al-complaint 1/4

WILLIE ()BERSON

VERSU

SALIH ApANALIC, SD TRUCKING,

INC., AN ACE AMERICANINSURA CE COMPANY* * * * * * * * * * * * * * * * * * * *

1 1

NUMBERIW\ \ DIVISION:

18 JUDICIAL DISTRICT COUR T

PARISH OF IBERVILLE

STATE OF LOUISIANA* * * * * * * * * * * * * * * * * * * * * * * * * * * * *

PETITION FOR D M GES

Th petition of Willie Roberson, a major individual, domiciled in the Parish of

East Bato Rouge, State of Louisiana, respectfully represents:

1.

Ma e defendants herein are:

1) ALIH ADANALIC a major individual domiciled at 3227 Highgate Ave.

SW, Wyoming, MI 49509;

SD TRUCKING INC. a foreign corporation not authorized to do but

doing business in the State of Louisiana with its principle place of business

located at 12337 East D Ave., Richland, MI 49083; and

ACE AMERICAN INSURANCE COMPANY a foreign insurance

company authorized to do and doing business in the Parish of East Baton

Rouge, State of Louisiana.

2.

Defe ants, Salih Adanalic, SD Trucking, Inc., and Ace American Insurance

Company ar justly and truly indebted, in solid°, unto petitioner in an amount that is just

and reasonab e under the premises, for all elements of damage allowed by Louisiana law,

with legal int rest thereon from date of judicial demand until paid, and for all costs of

these proceed ngs, for the following, to wit:

3.

On or out January 18, 2014 plaintiff Willie Roberson was operating a 2009

Chevrolet Imp la and traveling north on La. Highway 30 in the Parish of Iberville, State

of Louisiana a d was stopped at the intersection of La. Highway 30 and Bayou Paul Lane

at the red light. Thereafter a 2005 eighteen wheel tractor trailer, owned by SD Trucking,

Case 3:15-cv-00720-SDD-SCR Document 1-1 10/28/15 Page 1 of 17

A



Inc. and o crated by Salih Adanalic, which was also traveling north on La. Highway 30,

entered th intersection of La. Highway 30 and Bayou Paul Lane and stopped, reversed

his vehicl and backed into plaintiffs automobile.

4.

Du1 to the above-described accident, plaintiff sustained painful injuries, including

but not li ted to injuries to his lumbar spine, left leg and knee.

5.

The above-described accident and plaintiffs resulting injuries were proximately

caused by t e fault and negligent acts and omissions of Salih Adanalic, in the following

non-exclus ye particulars:

1) Breach of a legally imposed duty of reasonable care;

2) Failure to see what he should have seen and observe the vehicle located

behind him;

3) Failing to take proper evasive action;

4) Negligently entering the intersection against the traffic control sign;

5) Operating his vehicle in a careless and inattentive manner;

6) Violation of statutes enacted in Title 32 of the Louisiana RevisedStatutes;

7) Negligently backing his vehicle into plaintiffs vehicle; and

8) Other negligent acts and omissions to be proved at the trial of this cause.

6.

At al times pertinent hereto, specifically on or about January 18, 2014, Salih

Adanalic w employed by and acting within the course and scope of his duties with SD

Trucking, In which, by the virtue of the doctrine of respondent superiorand Louisiana

Civil Code rticle 2320, is liable, in solid°, with its employee, Salih Adanalic, and for his

negligent ac u and/or omissions and for all amounts owed to plaintiff.

2




7.

At the time of the above-described accident, defendant Ace American Insurance

1

Company 1 ad in full force and effect, a policy of automobile liability insurance, policy

number CT788268-5012-122 providing coverage to defendant, Salih Adanalic, as

operator of the aforesaid vehicle and therefore, Ace American Insurance Company is

liable, in solid°, with its insured for all amounts due to plaintiff pursuant to Louisiana

Revised Sta te 22:1269.

8.

Plain iff Willie Roberson claims such damages that are just and reasonable under

the premise , for damages, past, present, and future, for mental anguish, emotional

distress, paii and suffering, medical bills, loss of enjoyment of life, lost wages, loss of

wage earnin capacity, physical disability and all other elements of damages allowed by

Louisiana la

9.

Plaint ff respectfully requests written notice to his counsel ten days in advance of

the date fixei for trial or hearing on any exception, motion, rule or trial on the merits in

this proceedi g pursuant to Louisiana Code of Civil Procedure Article 1572, and plaintiff

further reque ts pursuant to Louisiana Code of Civil Procedure Articles 1913 and 1914

immediate n ice to his counsel of all interlocutory and final orders and judgments on any

exceptions, otions, rules or trial on the merits in these proceedings.

WHE FORE, plaintiff Willie Roberson prays that defendants Salih Adanalic,

SD Trucking, Inc., and Ace American Insurance Company be duly cited and served with

this Petition f r Damages, be required to appear and answer same and, after the expiration

of all legal de ays and due proceedings had, that there be judgment rendered herein in

favor of petitioner, and against defendants, for all such damages as are reasonable in the

premises, with legal interest thereon from date of judicial demand until paid, for all costs

of these proce dings, and for all other general and equitable relief.

3




2015 JAN 1 2 P12: 5/s/Kriste n B. Crowson

-EX OFFICIALE. LOUISIANA

D Y C L E RIBERVIL

4

Respectfully. submitted:

BOHRER LAW FIRM, L.L.C.8712 Jefferson Highway, Suite BBaton Rouge, LA 70809Tel: (225)925-5297

Phili Bo rerBar oil o: 14089

By:

SERVIC INFORMATION:

Please se e:

Salih Ad alic via long arm statute)3227 Hig gate Ave SWWyoming, MI 49509

-an

SD Trucki 1 g, Inc. via long arm statute)Through it agent for service of process:Sean Devr u12337 East D Ave.Richland, d49083

-and

Ace Americ Insurance CompanyThrough its gent for service of process:Louisiana S;cretary of State3851 Essen I aneBaton Roug LA 70809

FLED


Documents

ROBERSON v. ADANALIC et al complaint