Date: 08-04-2014

Case Style: Brenda Smolen v. Cheyene Fletcher and Amanda Marie Ruyle

Case Number: CJ-2012-836

Judge: Daman H. Cantrell

Court: District Court, Tulsa County, Oklahoma

Plaintiff's Attorney: Oleg Roytman and Ryan Harper

Defendant's Attorney: Kurt Hoffman

Description: Brenda Smolen v. Cheyene Fletcher and Amanda Marie Ruyle

COMES NOW the Plaintiff, Brenda Smolen and for her cause of action against the Defendant, Cheyenne Fletcher, state as follows:
PARTIES. JURISDICTJON AND VENUE
1. The Plaintiff, Brenda Smolen is a resident of Tulsa County, Oklahoma.
2. The Defendant, Cheyenne Fletcher is a resident of Tulsa County, Oklahoma.
3. The accident and injuries that are the subject of this dispute occurred in Tulsa County, Oklahoma,
4. This Court has jurisdiction and venue is proper in Tulsa County, State of Oklahoma.
FACTS COMMON TO ALL CLMMS
5. Paragraphs 1-4 are incorporated herein by reference.
6. On or around February 16, 2010, the Defendant while in Tulsa County, Oklahoma negligently
struck the Plaintiff
7 The force exerted on the Plaintiff caused severe injury to her
CAUSE OF ACTION
(Negligence Against Cheyenne Fletcher)
8. Paragraphs 1-7 are incorporated herein by reference,
9. The Defendant owed a duty to the Plaintiff and all othet drivers on the road, to operate the vehicle under her control in a safe and reasonable manner, using ordinary care to prevent injury to other persons and to keep a lookout consistent with the safety of other vehicles.
10. By failing to operate the vehicle in such a way, and by acting recldessly with complete disregard for the health and well-being of the Plaintiff and all other drivers on the road, the Defendant breached the duty owedto the Plaintiff.
11. This breach by the Defendant was the actual and proximate cause of Plaintiff’s injuries.
12. As a result of Defendant’s negligence, the Plaintiff has suffered personal injury, including medical expenses, mental and physical pain and suffering, and other actual damages in excess of
$75,000.00.
WHEREFORE, based on the foregoing, the Plaintiff prays that this Court grant him the relief sought including, but not limited to, actual damages in excess of Seventy-Five Thousand Dollars ($75,000.00), with interest accruing from date of filing of suit, punitive damages in excess of Seventy- five Thousand Dollars ($75,000.00), reasonable attorneys fees, and all other relief deemed appropriate by this Court.

The Defendant, Cheyenne Fletcher and Amanda Marie Ruyle, pursuant to 12 0.S. §
1101, offers to allow judgment be taken in the above-styled action in the total amount of Fifteen
Thousand and One 00/100 Dollars ($$15,001.00), as to any and all claims made by BRENDA
SMOLEN, individually, inclusive of prejudgment interest, costs, and attorney fees.

Outcome: Settled for %15,001 and dismissed with prejudice.

Plaintiff's Experts:

Defendant's Experts:

Comments: