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Date: 07-10-2015

Case Style: Johnny LaPlant and Edgar Martin v. Angel Jacque

Case Number: CJ-2015-1103

Judge: Jefferson D. Seller

Court: District Court, Tulsa County, Oklahoma

Plaintiff's Attorney: Don Smolen

Defendant's Attorney: No Appearance

Description: Tulsa, OK - Johnny LaPlant and Edgar Martin sued Angel Jacque on an auto negligence theory claiming:

1. That the Plaintiffs are residents of Tulsa County, State of Oklahoma; and that Defendant, ANGEL JACQUE, is a resident of Tulsa County, State of Oklahoma. That the complaint alleged
herein occurred in Tulsa County, State of Oklahoma, and that this Court has jurisdiction over the
parties and the subject matter herein
FIRST CAUSE OF ACTION
2. On December 12, 2014, on private property located at East 4 Street and North Denver
Avenue in Tulsa, Oklahoma, the Defendant, ANGEL JACQUE, negligently drove his vehicle into the vehicle driven by Plaintiff, JOHNNY LAPLANT, when the accident occurred.
3. As a result of the negligence of the Defendant, ANGEL JACQUE, Plaintiff, JOHNNY
LAPLANT, was injured and his injuries are permanent, painful and progressive. When injured, Plaintiff, JOHNNY LAPLANT, was 50 years of age with a life expectancy of 26.0 more years according to the U. S. Census Bureau, Statistical Abstract of the United States: 2012.
4. As a result of the injuries, Plaintiff, JOHNNY LAPLANT, has and will incur medical expenses, has and will suffer pain of mind and body, has sustained permanent injury, has and will lose wages and has had his earning capacity impaired.
WHEREFORE, Plaintiff, JOHNNY LAPLANT, prays for judgment against the Defendant, ANGEL JACQUE, in an amount in excess of the amount required for diversityjurisdiction pursuant to Section 1332 of Title 28 of the United States Code together with the costs of this action.
SECOND CAUSE OF ACTION
1. COMES NOW the Plaintiff; EDGAR MARTIN, and for the SECOND CAUSE OF
ACTION, hereby re-adopts and re-alleges the allegations contained within paragraphs 1-4 of the
FIRST CAUSE OF ACTION as if fully re-stated herein, and further states and alleges as follows:
2. That Plaintiff, EDGAR MARTIN, was a passenger in the automobile driven by Co-Plaintiff, JOHNNY LAPLANT.
3. As a result of the negligence of the Defendant, ANGEL JACQUE, Plaintiff; EDGAR MARTIN, was injured and his injuries are permanent, painful and progressive, When injured, Plaintiff, EDGAR MARTIN, was 83 years of age with a life expectancy of 5.7 more years according to the U. S. Census Bureau, Statistical Abstract of the United States: 2012.
4. As a result of the injuries, Plaintiff, EDGAR MARTIN, has and will incur medical expenses, has and will suffer pain of mind and body, and has sustained permanent injury.

Outcome: Settled for an undisclosed sum and dismissed with prejudice.

Plaintiff's Experts:

Defendant's Experts:

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