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NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
New Case Electronically Filed: COMPLAINT
June 15,2022 09:28
By: JOSEPH J. DARWAL 0092456
Confirmation Nbr. 2576534
TALIA JOHNSON CV 22 964736
vs.
Judge: RICHARD A. BELL
FREDDIE LANE
Pages Filed: 4
Electronically Filed 06/15/2022 09:28 // CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD
IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
TALIA JOHNSON CASE NO.
5153 Cato Street
Maple Heights, Ohio 44137,
JUDGE
Plaintiff,
vs.
COMPLAINT
FREDDIE LANE
5151 Lee Road
Maple Heights, Ohio 44137, (Jury Demand Endorsed Hereon)
Defendant.
Now comes the Plaintiff, TALIA JOHNSON, by and through undersigned counsel, and for
his Complaint against the Defendants states as follows:
1. All activities giving rise to this Complaint occurred within the City of Cleveland, County of
Cuyahoga, and State of Ohio.
2. The Defendant, Freddie Lane, resided in the City of Maple Heights, Cuyahoga County, Ohio at all
times relevant herein.
3. At all times relevant hereto, the Plaintiff resided at the address captioned above in Cuyahoga
County, Ohio.
4. Venue in Cuyahoga County is proper under Ohio law.
COUNT I: PERSONAL INJURY CLAIM OF TALIA JOHNSON:
OI3RAL, SILK 5. Plaintiffs restate all of their foregoing allegations as if fully rewritten at length herein.
&
PAI,, LLC
ATfORNHYS AT J .AW 6. On or near Lee Rd. and Harvard Ave, in the City of Cleveland, in the County of Cuyahoga, State of
55 Public Square
Suite #1700
Cleveland, OtJidtllj
210-LAWWRS
Ohio on 06/26/2020, Defendant Freddie Lane negligently and/or recklessly operated a motor vehicle
/ CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD
Electronica lly Filed 06/15/2022 09:28 /
thereby causing personal injury to Plaintiff Taiia Johnson, who was a passenger in vehicle being
operated in a lawful manner and with due care and caution for traffic and other surrounding
circumstances.
7. At that time and place, the Defendant, Freddie Lane, committed one or more of the following acts
of negligence in the operation of his vehicle:
A. Negligently failing to keep his automobile under
proper control;
B. Operating a vehicle in a negligent and careless manner;
C. Negligently failing to stop his vehicle when he could see that
danger to the Plaintiff was imminent;
D. Negligently operating his vehicle at a speed excessive
for the existing road conditions;
E. Operating his vehicle at a speed greater than would
permit him to stop within the assured clear distance
ahead;
F. Negligently colliding with the vehicle Plaintiff was in;
G. Operating his vehicle while distracted by his
cellular device and/or other electronic device which distracted
or diverted his attention from operating his motor
vehicle safely.
H. Otherwise violating the basic rules of the road designed for
...... the safety :md security of all persons, including the Plaint ilf.-- - -
8. As a direct and proximate result of Defendant’s negligent and/or reckless acts, Plaintiff, Talia
Johnson, suffered mental anguish, pain and suffering and emotional distress and will continue to
suffer mental anguish, pain and suffering and emotional distress into the future.
9. As a direct and proximate result of the Defendant’s negligent and/or reckless acts, Plaintiff, Talia
OBRAL, SILK
&
PAL, LLC Johnson, sustained injury to her person requiring medical treatment and incurred medical expenses
ATTORNEYS AT LAW
55 Public Square
Suite in the past and he will continue to require medical treatment and incur medical expenses into the
Cleveland, Otic 44113
Jltj-LAWYliRS
future.
2.
Electronica y Filed 06/15/2022 09:28 / / CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD
10. As a direct and proximate result of the Defendant’s negligent and/or reckless acts, Plaintiff, Talia
Johnson, lost wages in the past and expects to sustain lost wages into the future. Plaintiffs earning
capacity has been permanently impaired.
11. As a direct and proximate result of the Defendant’s negligent and/or reckless acts, Plaintiff, Talia
Johnson, incurred undetermined miscellaneous expenses relating to bodily injury or property loss
in the past and expects to incur miscellaneous expenses into the future including but not limited to
diminution in value, as applicable.
12. The Plaintiff sustained a permanent and substantial physical deformity and/or the loss of use of a
normal bodily system or function, and as such, her non-economic damages are not capped by statute.
WHEREFORE, the Plaintiff, Talia Johnson, demands judgment against Defendant, Freddie
Lane, in an amount IN EXCESS OF TWENTY-FIVE THOUSAND DOLLARS ($25,000.00) in
compensatory damages, together with her costs, fees and reasonable attorney’s fees, which will fully
and fairly compensate her for her injuries, and such other and further relief as this Court deems just
and equitable.
Respectfully submitted,
/s/ Joseph J. Darwal
JOSEPH J. DARWAL (0092456)
OBRAL, SILK & PAL, LLC
55 Public Square, Suite 1700
Cleveland, Ohio 44113
(216) LAWYERS (529-9377)
(216) 696-3228 - Facsimile
jdarwal@2161awyers.com
OBRAL, SILK
*
PAL, LLC
ATTORNEYS AT LAW
55 I’uhlic Squnru
Suilc#l700
Cleveland. Ohio M4113
2L6-LAWYERS
3.
Electronica ly Filed 06/15/2022 09:28 // CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD
JURY DEMAND
The Plaintiff respectfully requests a trial by the maximum number of jurors permitted
by Ohio Law.
/s/ Joseph J. Darwal
JOSEPH J. DARWAL (0092456)
ATTORNEY FOR PLAINTIFF
OBRAL, SILK & PAL, LLC
OBRAL, SILK
&
PAL, LLC
ATTORNEYS AT LAW
55 Public Square
Suite #1700
ClcvclfttixL, Ohio 44113
216-I.AWYERS
4.
Electronic; ly Filed 06/15/2022 09:28 // CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD
Preview
NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas New Case Electronically Filed: COMPLAINT June 15,2022 09:28 By: JOSEPH J. DARWAL 0092456 Confirmation Nbr. 2576534 TALIA JOHNSON CV 22 964736 vs. Judge: RICHARD A. BELL FREDDIE LANE Pages Filed: 4 Electronically Filed 06/15/2022 09:28 // CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO TALIA JOHNSON CASE NO. 5153 Cato Street Maple Heights, Ohio 44137, JUDGE Plaintiff, vs. COMPLAINT FREDDIE LANE 5151 Lee Road Maple Heights, Ohio 44137, (Jury Demand Endorsed Hereon) Defendant. Now comes the Plaintiff, TALIA JOHNSON, by and through undersigned counsel, and for his Complaint against the Defendants states as follows: 1. All activities giving rise to this Complaint occurred within the City of Cleveland, County of Cuyahoga, and State of Ohio. 2. The Defendant, Freddie Lane, resided in the City of Maple Heights, Cuyahoga County, Ohio at all times relevant herein. 3. At all times relevant hereto, the Plaintiff resided at the address captioned above in Cuyahoga County, Ohio. 4. Venue in Cuyahoga County is proper under Ohio law. COUNT I: PERSONAL INJURY CLAIM OF TALIA JOHNSON: OI3RAL, SILK 5. Plaintiffs restate all of their foregoing allegations as if fully rewritten at length herein. & PAI,, LLC ATfORNHYS AT J .AW 6. On or near Lee Rd. and Harvard Ave, in the City of Cleveland, in the County of Cuyahoga, State of 55 Public Square Suite #1700 Cleveland, OtJidtllj 210-LAWWRS Ohio on 06/26/2020, Defendant Freddie Lane negligently and/or recklessly operated a motor vehicle / CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD Electronica lly Filed 06/15/2022 09:28 / thereby causing personal injury to Plaintiff Taiia Johnson, who was a passenger in vehicle being operated in a lawful manner and with due care and caution for traffic and other surrounding circumstances. 7. At that time and place, the Defendant, Freddie Lane, committed one or more of the following acts of negligence in the operation of his vehicle: A. Negligently failing to keep his automobile under proper control; B. Operating a vehicle in a negligent and careless manner; C. Negligently failing to stop his vehicle when he could see that danger to the Plaintiff was imminent; D. Negligently operating his vehicle at a speed excessive for the existing road conditions; E. Operating his vehicle at a speed greater than would permit him to stop within the assured clear distance ahead; F. Negligently colliding with the vehicle Plaintiff was in; G. Operating his vehicle while distracted by his cellular device and/or other electronic device which distracted or diverted his attention from operating his motor vehicle safely. H. Otherwise violating the basic rules of the road designed for ...... the safety :md security of all persons, including the Plaint ilf.-- - - 8. As a direct and proximate result of Defendant’s negligent and/or reckless acts, Plaintiff, Talia Johnson, suffered mental anguish, pain and suffering and emotional distress and will continue to suffer mental anguish, pain and suffering and emotional distress into the future. 9. As a direct and proximate result of the Defendant’s negligent and/or reckless acts, Plaintiff, Talia OBRAL, SILK & PAL, LLC Johnson, sustained injury to her person requiring medical treatment and incurred medical expenses ATTORNEYS AT LAW 55 Public Square Suite in the past and he will continue to require medical treatment and incur medical expenses into the Cleveland, Otic 44113 Jltj-LAWYliRS future. 2. Electronica y Filed 06/15/2022 09:28 / / CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD 10. As a direct and proximate result of the Defendant’s negligent and/or reckless acts, Plaintiff, Talia Johnson, lost wages in the past and expects to sustain lost wages into the future. Plaintiffs earning capacity has been permanently impaired. 11. As a direct and proximate result of the Defendant’s negligent and/or reckless acts, Plaintiff, Talia Johnson, incurred undetermined miscellaneous expenses relating to bodily injury or property loss in the past and expects to incur miscellaneous expenses into the future including but not limited to diminution in value, as applicable. 12. The Plaintiff sustained a permanent and substantial physical deformity and/or the loss of use of a normal bodily system or function, and as such, her non-economic damages are not capped by statute. WHEREFORE, the Plaintiff, Talia Johnson, demands judgment against Defendant, Freddie Lane, in an amount IN EXCESS OF TWENTY-FIVE THOUSAND DOLLARS ($25,000.00) in compensatory damages, together with her costs, fees and reasonable attorney’s fees, which will fully and fairly compensate her for her injuries, and such other and further relief as this Court deems just and equitable. Respectfully submitted, /s/ Joseph J. Darwal JOSEPH J. DARWAL (0092456) OBRAL, SILK & PAL, LLC 55 Public Square, Suite 1700 Cleveland, Ohio 44113 (216) LAWYERS (529-9377) (216) 696-3228 - Facsimile jdarwal@2161awyers.com OBRAL, SILK * PAL, LLC ATTORNEYS AT LAW 55 I’uhlic Squnru Suilc#l700 Cleveland. Ohio M4113 2L6-LAWYERS 3. Electronica ly Filed 06/15/2022 09:28 // CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD JURY DEMAND The Plaintiff respectfully requests a trial by the maximum number of jurors permitted by Ohio Law. /s/ Joseph J. Darwal JOSEPH J. DARWAL (0092456) ATTORNEY FOR PLAINTIFF OBRAL, SILK & PAL, LLC OBRAL, SILK & PAL, LLC ATTORNEYS AT LAW 55 Public Square Suite #1700 ClcvclfttixL, Ohio 44113 216-I.AWYERS 4. Electronic; ly Filed 06/15/2022 09:28 // CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD