Beth Ann Warren-Hall v. Sofia Southarath

Oklahoma City, Oklahoma personal injury lawyers represented the Plaintiff on an auto negligence car wreck case.

COMES NOW the Plaintiff Beth Warren, and for her Petition and cause of action against

the above-named Defendant alleges and states as follows:

1. Beth Warren is a resident of Cleveland County, State of Oklahoma.

2. Defendant, Sofia Southarath is a resident of Oklahoma County, State of Oklahoma.

3. Defendant Sofia Southarath was driving her vehicle when she ran a STOP sign and

crashed into Plaintiff Warren near NW 27th Street and Mc.Kinley, in Oklahoma City, Oklahoma

County, Oklahoma, on October 10, 2019.

4. Jurisdiction is proper in Oklahoma County, Oklahoma.

5. Venue is proper in Oklahoma County, OK District Court.

STATEMENT OF FACTS

6. All preceding statements of plaintiffs complaint are incorporated herein and realleged

as if expressly set forth herein.

7. Upon information and belief, on or about October 10, 2019, Defendant Southarath

was driving a vehicle, owned by Defendant, on or near NW 27th Street and McKinley, in

Oklahoma City, Oklahoma County, Oklahoma.

8. Defendant Southarath had a duty to operate her vehicle with due care in order to

protect the safety of other drivers and passengers on the public roadways, including Plaintiff

who was also driving on or near NW 27th Street and McKinley, in Oklahoma City, Oklahoma

County, Oklahoma.

9. Defendant Southarath failed to yield the right of way when she ran a STOP sign

and crashed into Plaintiff Warren's vehicle.

10. Defendant Southarath caused detriment/damage to Plaintiff Warren's vehicle.

11. Defendant Southarath caused detriment/damage including but not limited to

physical and mental injury and pain and suffering to Plaintiff Warren and her pet who was riding

in Plaintiff's car.

12. Defendant SoutharNEGLIGENCE

13. Defendant Southarath's negligent, careless, reckless, erratic, and wanton operation

of her vehicle caused her to crash into Plaintiff Warren's vehicle.

14. The crash was caused by the negligence and the careless driving of Defendant

Southarath.

15. Plaintiff Warren was severely injured as a result of being crashed into by Defendant

Southarath.

16. Plaintiff Warren acted as an ordinary, reasonable person would.

17. Plaintiff Warren did nothing to cause the crash.

18. Plaintiff Warren did not fail to act contributing to causing the crash.

19. All preceding statements and allegations of Plaintiffs complaint are incorporated

herein and realleged as if expressly set forth herein.

20. At the time of the crash, Defendant Southarath failed to exercise due care by

driving her vehicle carelessly and erratically, failing to maintain control of her vehicle, driving

too fast for conditions, failing to keep a proper look-out, driving in a reckless manner, failing to

observe a traffic control device (STOP sign) and disregarding the actual and potential hazards

then existing.

21. At the time and place of the collision, Defendant Southarath was generally

negligent under the circumstances then and there existing in that she:

a. Failed to keep her vehicle under control;

b. Failed to keep a proper lookout;

c. Failed to yield the right of way;

d. Failed to devote her full time and attention to driving;

e. Failed to timely apply her brakes, alter direction of travel, or take any other

appropriate action when she, by the exercise of due and reasonable care, should have seen the

Plaintiff and other vehicles on the roadway;

f. Failed to operate her vehicle in a safe and prudent manner in view of the

conditions which existed at the time of the crash;

g. Operated her vehicle at an excessive speed;

h. Failed to operate her vehicle in a manner with due care and consideration of

the safety and lives of the other drivers and passengers lawfully on the road;

1. Drove in a reckless manner who was driving her vehicle in a careless, negligent, reckless,

wanton, erratic, and dangerous manner.

J. Such other actions or inactions that may be shown at a hearing of the cause.

22. Defendant Southarath's negligence proximately caused the crash with Plaintiff

Warren's vehicle and resulting damages and injuries to Plaintiff Warren and her pet.

23. At the time and place of the crash, Defendant Southarath was negligent per se in that

she was violating one or more of the statutes of the State of Oklahoma and or local city ordinances;

to include but not be limited to the following violations of the Oklahoma "Rules of the Road":

a. 47 O.S. § 11-102. Required Obedience to Traffic Laws;

b. 47 O.S § 11-201. Obedience to and Required Traffic-Control Devices;

c. 47 O.S. § 11-504. Drivers to Exercise Due Care;

d. 47 O.S. § 11-801. Basic Rule- Maximum [Speed] Limits;

e. 47 O.S. § 11-901. Reckless Driving;

f. 47 O.S. § 11-901 b. Failure to Devote Full Time and Attention;

24. As a result of Defendant Southarath's negligence, Plaintiff Warren will incur future

medical expenses for her injuries.

25. As a result of Defendant Southarath's negligence, Plaintiff Warren endures past,

present and future pain and suffering.

26. As a result of the Defendant's negligence, and Defendant's negligence per se, Plaintiff

Warren suffered the loss of past, present and future wages and/or income and other economic loss.

27. Plaintiff Warren has suffered both economic and non-economic loses as may be

shown at the hearing of the matter.

g. Court costs, attorney fees and all such further and general relief which the Court

deems just and proper.

5-20-2025 CTFREE





JUDGE OGDEN: CASE COMES ON FOR DAY TWO OF JURY TRIAL-- TRIAL RECOMMENCED AFTER NIGHT'S RECESS: PLAINTIFF, BETH WARREN IS PRESENT W/ HER COUNSELS, MARK WILSON AND KEN ADAIR. DEFENDANT, SOFIA SOUTHARATH APPEARS THROUGH HER COUNSELS, MATTHEW MCDEVITT AND KARA ELLISON: PARTIES ANNOUNCED READY: 23 PROSPECTIVE JURORS ARE PRESENT: DEFENDANT INQUIRE OF JURORS AND PASS FOR CAUSE: VOIR DIRE IS COMPLETED: BOTH SIDES ANNOUNCE THEIR 3 PREMPTORY CHALLENGES: THIRTEEN JURORS ARE SWORN IN TO TRY THE CASE: PLAINTIFF AND DEFENDANT GIVE THEIR OPENING STATEMENTS: PLAINTIFF'S CASE IN CHIEF: PLTFS CALLS THEIR FIRST WITNESS, JOSH HALL: WITNESS SWORN IN, EXAMINED: CROSS-EXAMINED: PLTF'S SECOND WITNESS, BETH WARREN: WITNESS SWORN: EXAMINED: CROSS-EXAMINED: PLTF CALL HER THIRD WITNESS, DR. ROB BROWN: WITNESS SWORN: EXAMINED: CROSS-EXAMINED: PLAINTIFF RESTS: JURORS ARE EXCUSED UNTIL 05-21-2025 AT 10:30AM: DEFT MOVES FOR DIRECTED VERDICT, WHICH IS DENIED: COURT IS IN RECESS UNTIL 05-21-2025 AT 9AM FOR COUNSEL TO CONDUCT JURY INSTRUCTIONS NEXT DAY

--COURT REPORTER, MARILYN HODGEN IS PRESENT--



Plaintiff's verdict for $1.5 million.







JUDGE OGDEN: CASE COMES ON FOR DAY THREE OF JURY TRIAL- TRIAL RECOMMENCED AFTER NIGHT'S RECESS: PLAINTIFF, BETH WARREN IS PRESENT W/ HER COUNSELS, MARK WILSON AND KEN ADAIR. DEFENDANT, SOFIA SOUTHARATH APPEARS THROUGH HER COUNSELS, MATTHEW MCDEVITT AND KARA ELLISON: PARTIES ANNOUNCED READY: JURY INSTRUCTIONS CONFERENCE CONDUCTED: THIRTEEN JURORS RETURNED AND SEATED IN THE JURY BOX: JURY IS INSTRUCTED ON THE LAW: PLAINTIFF AND DEFENDANT GIVE THEIR CLOSING ARGUMENTS: JURY RETIRES TO DELIBERATE: JURY RETURNS A VERDICT IN FAVOR OF THE PLAINTIFF IN THE AMOUNT OF $1.5MIL : JURORS ARE THANKED FOR THEIR SERVICE AND DISMISSED: COURT IS ADJOURNED

--COURT REPORTER, MARILYN HODGEN IS PRESENT--