Date: 11-01-2012
Case Style: Johnny E. Littlejohn v. Amber D. Krenning
Case Number: CJ-2011-333
Judge: Tom A. Lucas
Court: District Court Cleveland County, Oklahoma
Plaintiff's Attorney: James Allen Belote
Defendant's Attorney: Lacy N. Boyles
Description: Plaintiff, Johnny E. Littlejohn, for his cause of action against the Defendant, alleges and states as follows:
1. On or about May 12, 2009, Defendant Amber D. Krenning was driving eastbound on SW near Briar Hollow Dr. in Cleveland, Oklahoma.
2. Mr. Littlejohn was also traveling eastbound on SW 134th and had stopped to turn left onto Briar Hollow Dr., when he was rear-ended by the Defendant.
3. As a direct result of the collision, Mr. Littlejohn suffered multiple injuries.
4. Mr. Littlejohn has no fault in this collision. Defendant was negligent in one or more ofthe following particulars, including but not limited to:
a. Failure to devote full time and attention to her vehicle; and
b. Following too closely.
5. Defendant violated 47 0.5. § 11-310 and is guilty of negligence per-se.
6. As a direct result of the negligence of the Defendant, Mr. Littlejobn suffered damages in excess of the sum of Seventy-Five Thousand Dollars ($75,000). Plaintiff claims damages for the physical pain and suffering, past and future; mental pain and suffering, past and future; permanent injury, lost wages, loss of earning capacity and for the reasonable and necessary medical expenses, past and future.
WHEREFORE, Plaintiff Johnny E. Littlejohn prays for judgment against the Defendant in an amount in excess of Seventy-Five Thousand Dollars ($75,000), and for costs, attorney fees, and such further relief to which he is entitled.
Defendant answered as follows:
1.
The Defendant is without sufficient information and/or knowledge to admit or deny the allegations contained in Paragraphs 2, 3, 4, and 5 of Plaintiffs Petition and demands strict proof thereof
2.
The Defendant admits those allegations and claims contained in Paragraph 1 of Plaintiffs Petition.
3.
The Defendant specifically denies those allegations and claims contained in Paragraph 6 of Plaintiffs Petition and demand strict proof thereof
AFFIRMATIVE DEFENSES
COMES NOW Defendant, AMBER D. KRENNING, and states the following affirmative defenses to the Petition filed by Plaintiff herein:
4.
Whether the Plaintiff suffers from any pre-existing or post-arising medical condition will be developed during discovery and Defendant herein reserves all defenses in that regard.
5.
Whether the Plaintiff has acted to mitigate his damages will be developed during discovery and Defendant herein reserves all defenses in that regard.
6.
Additional defenses may be developed during discovery. Defendant reserves the right to supplement andlor amend this Answer in accordance with the Court’s Scheduling Order.
WHEREFORE, having fully answered, Defendant prays that Plaintiff takes nothing by way of his Petition herein and that Defendant be dismissed with costs and attorney fees and any other relief this Court may deem equitable and just.
Outcome: Settled and dismissed with prejudice.
Plaintiff's Experts:
Defendant's Experts:
Comments: