Kevin Hahn v. Norman Police Department and City of Norman

Oklahoma City, Oklahoma personal injury lawyer represented the Plaintiff on a Governmental Tort Claim Act auto negligence claims.



COMES NOW Plaintiff, Kevin Hahn, and for his cause of action against the Defendants,

Norman Police Department (herein after "Defendant Police Department") and City of Norman,

alleges and states:

THE PARTIES

1. Plaintifl: Kevin Hahn, was a citizen and resident of the State of Oklahoma at the time

of the collision hereinafter described.

2. At all material times mentioned herein, Defendant Police Department and

Defendant City of Norman, are and were a police department and municipality, respectively,

located in Cleveland County, State of Oklahoma.

GOVERNMENTAL TORT CLAIMS ACT

3. In compliance with the Governmental Torts Claims Act, Plaintiff timely filed notice

of their claim in writing to Defendant Police Department and Defendant City of Norman, which

was received on August 3, 2020.4. The claim is deemed denied by Defendant Police Department and Defendant City

of Nonnan, pursuant to 51 O.S. § 157, because Defendant Police Department and Defendant City

ofNonnan failed to respond within ninety (90) days of the notice.

5. Plaintiff timely filed this action within 180 days of the date of the denial on or

before April 30, 2021.

6. The Plaintiff has complied with all requirements under the Oklahoma

Governmental Tort Claims Act, 51 O.S. § 151 et. seq.

JURISDICTION A!'lD VENUE

7. This is an action arising from a motor vehicle accident that occurred on February

l 0, 2020, in Oklahoma County, Oklahoma, Edward Nickerson negligently drove a Norman Police

Department patrol vehicle and struck the vehicle operated by Plaintiff, Kevin Hahn.

8. This Court has jurisdiction over the parties hereto, jurisdiction of the subject matter

hereof, and venue is proper.

FIRST CAUSE OF ACTION: NEGLIGENCE

9. That on or about February 10, 2020, Edward Nickerson was an employee of

Defendant Police Department in the capacity of patrol officer.

10. That on or about February 10, 2020, at or near 12th Ave SE and Woodcreek Drive

in Norman, Cleveland County, Oklahoma, Edward Nickerson negligently drove his Norman Police

Department patrol vehicle and struck the vehicle operated by Plaintiff, Kevin Hahn.

11 . As a result of the collision, Plaintiff, Kevin Hahn, suffered personal injuries and

incurred medical expenses.

12. Defendant Police Department and Defendant City of Norman, are vicariously liable

for the acts and/or omissions of its employees, agents, and/or servants while acting within their

scope of employment through the doctrine of respondeat superior.

13. That at all relevant times mentioned herein, Plaintiff operated his vehicle properly and

!av.fully.

14. That as a direct and proximate result of the negligence of Defendant Police

Department and Defendant City of Norman, Plaintiff has sustained bodily injuries; has incurred

medical expenses; has suffered pain and suffering~ and has incurred property damage all in an

amount in excess of $75,000.00.

WHEREFORE, Plaintiff, Kevin Hahn, prays for judgment against Defendants, Norman

Police Department and City of Norman, for personal injuries in an amount in excess of $75,000

plus interest, costs, and attorney fees, against Defendants, Norman Police Department and City of

Norman, and all such other and further relief as to which Plaintiff may be entitled.

Settled for $100,000.