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Date: 03-03-2016
Case Style: Leatricia Norwood v. Robert Scott Brown, Super Motors, Inc. and Brown's Construction Company, Inc.
Case Number: CJ-2015-318
Judge: Thomas E. Prince
Court: District Court, Oklahoma County, Oklahoma
Plaintiff's Attorney:
Defendant's Attorney: Stephanie Corbett for Robert Scott Brown and Brown Construction Company, Inc.
Randy Long for Super Motors, Inc.
Description: Oklahoma City, OK - Personal injury lawyer represented Plaintiff, Leatricia Norwood, who sued Robert Scott Brown, Super Motors, Inc. and Brown's Construction Company, Inc. on auto negligence and respondeat superior theories claiming:
1. That Plaintiff Norwood is a resident of Oklahoma County, State of Oklahoma.
2. That Defendant Brown is a resident of Oklahoma County, State of Oklahoma.
3. That Defendant Brown's Construction Company, Inc. is a domestic for profit business corporation.
4. That Defendant Super Motor is a domestic for profit business corporation.
5. That on the 30th day of September, 2013, in Arcadia, County of Oklahoma, State of Oklahoma, Plaintiff was driving a 1997 white Chevrolet Silverado, and operating her motor vehicle in a reasonable and prudent manner traveling westbound on Interstate 40 when Defendant Brown, in the course and scope of his employment and/or acting as an agent of Super
Motor and Brown's Construction Company, Inc., driving a 2002 white Ford 350, negligently and recklessly rear ended Plaintiff's vehicle.
6. That Defendant Brown was negligent in operating his vehicle which caused the collision complained of herein.
7. That Defendant Brown failed to devote full time and attention to his driving.
8. That Defendant Brown failed to operate his vehicle in a reasonable and proper manner.
9. That Defendant Brown was Negligent Per Se.
10. That the collision was directly and proximately caused by the negligence and intentional malicious and reckless acts of Defendant Brown.
11. At the time of the wreck Defendant Brown was in the course and scope of employment with Defendant Super Motor.
12. At the time of the wreck Defendant Brown was in the course and scope of employment with Defendant Brown's Construction Company, LLC.
13. At the time of the wreck Defendant Brown was in the course and scope of employment with Defendant Super Motors Inc.
14. That Defendant Brown's actions were intentional, malicious and/or reckless and warrant the imposition of punitive damages.
15. Prior to this collision, Plaintiff Norwood was in good health with a normal life expectancy, but as a direct and proximate result of the Defendants' actions, Plaintiff has sustained damages for which she is entitled to recover.
16. That Plaintiff Norwood did not cause or contribute to the cause of the wreck in any way whatsoever.
,
17. Pursuant to the provisions of 12 O.S. � 3226(8)(2), Plaintiff submits this preliminary computation of damages sought in this lawsuit. As this is an action for injuries suffered by an adult, Plaintiff advises that all damages recoverable by law are sought, including those listed in OUJI 2d 4.1. Under item (K), Plaintiff s medical bills incurred to date are
$8,041.03 at this time. At this point, Plaintiff does not know the amount of future medical expenses. These items are among the elements for the jury to consider in fixing the amount of damages to award Plaintiff. Other than the amounts which Plaintiff has specifically identified, and which are capable of being ascertained to some degree of certainty, Plaintiff is unable to guess or speculate as to what amount of damages a jury might award. The elements for the jury to consider include the following:
A. Plaintiff s physical pain and suffering, past and future;
B. Plaintiff s mental pain and suffering, past and future;
C. Plaintiff s age;
D. Plaintiff s physical condition immediately before and after the accident;
E. The nature and extent of Plaintiff s injuries;
F. Whether the injuries are permanent;
G. Toe physical impairment
H. The disfigurement;
I. Loss of [earning/time];
J. Impairment of earning capacity;
K. The reasonable expenses of the necessary medical care, treatment and services, past and future.
Outcome: Settled for an undisclosed sum and dismissed with prejudice.
Plaintiff's Experts:
Defendant's Experts:
Comments: