Date: 07-23-2014

Case Style: Stephanie Snell v. Robin Ladawn Williams

Case Number: CJ-2011-801

Judge: Tracy Schumacher

Court: District Court, Cleveland County, Oklahoma

Plaintiff's Attorney: Mark Matthews

Defendant's Attorney: Stephen Olson and Daniel J. Card

Description: Stephanie Snell v. Robin Ladawn Williams

1. Plaintiff, STEPHANIE SNELL, is a citizen and resident of Cleveland County, State of Oklahoma and was so on the date of the subject incident.
2. The Defendant, CAROLYN SNOW, is a citizen and resident of Garvin County, State of Oklahoma and was so on the date of the subject incident.
3. The date of the subject incidentlcollision is alleged to be May 22, 2009. The subject incident between the Plaintiff, STEPHANIE SNELL and the Defendant, CAROLYN SNOW occurred in Cleveland County, State of Oklahoma, and jurisdiction and venue over the parties and subject matter of this action are proper in Cleveland County, State of Oklahoma.
FIRST CAUSE OF ACTION
4. The Plaintiff alleges that on or about the above referenced date, Defendant, CAROLYN SNOW, drove her vehicle into the Plaintiffs vehicle while Plaintiff slowed for traffic on 1-35 Southbound and that said impact then drove Plaintiff’s vehicle into a school bus. Plaintiff alleges that the acts and/or conduct and/or omissions of the Defendant, CAROLYN SNOW caused the subject collision and the Plaintiffs resulting bodily injuries with no fault on the part of the Plaintiff. Plaintiff further alleges that the Defendant admitted fault for the subject collision at the scene of the incident.
5. The Plaintiff alleges the cause of her damages and injuries to be a result of the negligent acts and/or conduct and/or omissions of the Defendant, CAROLYN SNOW, and without any conduct on the part of the Plaintiff contributing thereto, in one or more of the following particulars, including, but not being limited to:
a. The Defendant failed to devote fill time and attention to the operation of a motor vehicle;
b. The Defendant failed to observe and/or obey the rules of the road, including the rules applicable to right-of-way of other drivers;
c. The Defendant failed to use the steering and/or braking mechanisms on the motor vehicle she was operating to avoid the subject collision;
d. The Defendant operated her motor vehicle in an unsafe and/or reckless manner.
e. The Defendant operated her motor vehicle too fast for conditions.
In addition to the common law acts of negligence above set forth, the Plaintiff alleges that the Defendant, CAROLYN SNOW, is liable under theories of negligence per se in that the Defendant’s acts and/or conducts and/or omissions are in violation of applicable statutoiy authority and/or municipal ordinances.
6. As a result of the negligence and/or recklessness of the Defendant, CAROLYN SNOW, the Plaintiff suffered permanent, painful and progressive physical injuries, both past and future.
Plaintiff has incuned, and will incur in the future, reasonable and necessary medical care and treatment and expense for the injuries and damages sustained in the subject collision. Plaintiff has sustained and/or realized loss of fmancial income and/or revenues, both past and future, and has sustained and/or will sustain loss of enjoyment of life as a result of injuries and damages, sustained in the subject collision all to her damage in a sum in excess of Ten Thousand Dollars ($10,000.00) actual damages exclusive of costs and interest.
WHEREFORE, the Plaintiff, STEPHANIE SNELL, prays for judgment against the Defendant, CAROLYN SNOW, on her First Cause of Action in a sum in excess of Ten Thousand Dollars ($10,000.00) actual damages, exclusive of costs and interest, together with the awarding of lawful costs, interest and other relief this Court deems just and proper. Plaintiff further states that her claim may exceed the sum of $75,000.00 and prays for alternative relief in excess of that amount.
SECOND CAUSE OF ACTION
COMES NOW the Plaintiff, STEPHANIE SNELL, and for her Second Cause of Action herein adopts by material reference, and re-alleges and re-states, En toto, incorporating all material allegations contained in this Petition and the First Cause of Action above and further alleges as follows and states:
7. The Defendant, CAROLYN SNOW, acted in a willful, wanton and/or reckless manner and in total disregard for the rights of the Plaintiff in particular, and the public in general. Such acts and/or omissions of the Defendant, CAROLYN SNOW, entitle the Plaintiff to an award of punitive damages as against the Defendant, CAROLYN SNOW. Plaintiff therefore prays the trier of fact to determine that the acts of the Defendant, CAROLYN SNOW, were reckless, and/or willful and/or wanton to such an extent that the Plaintiff is entitled and shall receive an award of punitive damages in excess of Ten Thousand Dollars ($10,000.00), exclusive of costs and interest from all Defendant herein.
WHEREFORE, the Plaintiff, STEPI-TANIE SNELL prays judgment on her Second Cause of Action in favor of the Plaintiff and against the Defendant, CAROLYN SNOW, Individually, for a sum in excess of Ten Thousand Dollars ($10,000.00) as punitive damages, exclusive of costs and interest, together with the awarding of lawful costs, interest and other relief this Court deems just, equitable and proper. Plaintiff further states that her claim may exceed the sum of $75,000.00 and prays for alternative relief in excess of that amount.

Outcome: Settled and dismissed with prejudice.

Plaintiff's Experts:

Defendant's Experts:

Comments: