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NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
REQUEST FOR SERVICE
October 28,2022 13:01
By: JOSEPH J. DARWAL 0092456
Confirmation Nbr. 2689201
TALIA JOHNSON CV 22 964736
vs.
Judge: KATHLEEN ANN SUTULA
FREDDIE LANE
Pages Filed: 6
Electronically Filed 10/28/2022 13:01 /SERVICE/CV 22 964736 /Confirmation Nbr. 2689201 /CLAHJ
Common Pleas Court of Cuyahoga County, Ohio
Nailah K. Byrd, Clerk of Courts
INSTRUCTIONS FOR SERVICE
Talia Johnson Case Number
--------------- i--
Plaintiff(s)
Kathleen Ann Sulula
Judge:
Vs.
Freddie Lane, Jr., et al. Date: 10/28/22
Defendants(s)
Method of Service Requested:
Certified Mail Service) | Ordinary Mail Service J Federal Express Service
Personal Service by the Sheriff of County
Residence Service by the Sheriff of County
Personal Service By Process Server
Residence Service by Process Server
Ngmefs) and Address(es) of Parties to Serve:
Freddie Lane, Jr., 9107 Laisy Avenue, Cleveland, Ohio 44104
Additional Instructions:
Please Serve the above Defendant with the Complaint via regular U.S. mail
Filing Party Name:JosePh -b Darwal Supreme Court ID if applicable: 0092456
Phone Number: 216-529-9377
For Use by Sheriff or Process Server Only
Number of Service Attempts:
^Xddress for Service if Different from address included above:
Electronically Filed 10/28/2022 13:01 / SERVICE / CV 22 964736 / Confirmation Nbr. 2689201 / CLAHJ
NAILAHK. 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
Electronically Filed 10/28/2022 13:01 / SERVICE / CV 22 964736 / Confirmation Nbr. 2689201 / CLAHJ
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 foe 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 foe 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;
OBRAL.80JC
5. Plaintiffs restate all of their foregoing allegations as if folly rewritten at length herein.
&
PAL.ue
MTCRXmATTJSW
6. On or near Lee Rd. and Harvard Ave, in the City of Cleveland, in foe County of Cuyahoga, State of
MMOtSfn
Mtofns
Ctata4CM»4aU
itMjunmi
Ohio on 06/26/2020, Defendant Freddie Lane negligently and/or recklessly operated a motor vehicle
1.
Electronic ly Filed 06/15/2022 09:28 / / CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD
Electronical1 Filed 10/28/2022 13:01 / SERVICE / CV 22 964736 / Confirmation Nbr. 2689201 I CLAHJ
thereby causing personal injury to Plaintiff Talia 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 Plaintiffwas 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-and-securi^of-albpersonsrincludingthe-Plaintiff. ’ - ■'
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
Johnson, sustained injury to her person requiring medical treatment and incurred medical expenses
in the past and he will continue to require medical treatment and incur medical expenses into the
future.
2.
Electronic!
OBRAUSiUC
y Filed 06/15/2022 09:28 / / CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD
ectronically
ElectronicallyFiled 10/28/202213:07 / SERVICE / CV 22 964736 / Confirmation Nbr. 2689201 / CLAHJ
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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. Darwcd
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
OBRAUSIUC
&
PAU LLC
ATTOSNKY3ATLAW
SStWOfipai
OcKi>«M.4
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NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas REQUEST FOR SERVICE October 28,2022 13:01 By: JOSEPH J. DARWAL 0092456 Confirmation Nbr. 2689201 TALIA JOHNSON CV 22 964736 vs. Judge: KATHLEEN ANN SUTULA FREDDIE LANE Pages Filed: 6 Electronically Filed 10/28/2022 13:01 /SERVICE/CV 22 964736 /Confirmation Nbr. 2689201 /CLAHJ Common Pleas Court of Cuyahoga County, Ohio Nailah K. Byrd, Clerk of Courts INSTRUCTIONS FOR SERVICE Talia Johnson Case Number --------------- i-- Plaintiff(s) Kathleen Ann Sulula Judge: Vs. Freddie Lane, Jr., et al. Date: 10/28/22 Defendants(s) Method of Service Requested: Certified Mail Service) | Ordinary Mail Service J Federal Express Service Personal Service by the Sheriff of County Residence Service by the Sheriff of County Personal Service By Process Server Residence Service by Process Server Ngmefs) and Address(es) of Parties to Serve: Freddie Lane, Jr., 9107 Laisy Avenue, Cleveland, Ohio 44104 Additional Instructions: Please Serve the above Defendant with the Complaint via regular U.S. mail Filing Party Name:JosePh -b Darwal Supreme Court ID if applicable: 0092456 Phone Number: 216-529-9377 For Use by Sheriff or Process Server Only Number of Service Attempts: ^Xddress for Service if Different from address included above: Electronically Filed 10/28/2022 13:01 / SERVICE / CV 22 964736 / Confirmation Nbr. 2689201 / CLAHJ NAILAHK. 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 Electronically Filed 10/28/2022 13:01 / SERVICE / CV 22 964736 / Confirmation Nbr. 2689201 / CLAHJ 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 foe 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 foe 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; OBRAL.80JC 5. Plaintiffs restate all of their foregoing allegations as if folly rewritten at length herein. & PAL.ue MTCRXmATTJSW 6. On or near Lee Rd. and Harvard Ave, in the City of Cleveland, in foe County of Cuyahoga, State of MMOtSfn Mtofns Ctata4CM»4aU itMjunmi Ohio on 06/26/2020, Defendant Freddie Lane negligently and/or recklessly operated a motor vehicle 1. Electronic ly Filed 06/15/2022 09:28 / / CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD Electronical1 Filed 10/28/2022 13:01 / SERVICE / CV 22 964736 / Confirmation Nbr. 2689201 I CLAHJ thereby causing personal injury to Plaintiff Talia 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 Plaintiffwas 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-and-securi^of-albpersonsrincludingthe-Plaintiff. ’ - ■' 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 Johnson, sustained injury to her person requiring medical treatment and incurred medical expenses in the past and he will continue to require medical treatment and incur medical expenses into the future. 2. Electronic! OBRAUSiUC y Filed 06/15/2022 09:28 / / CV 22 964736 / Confirmation Nbr. 2576534 / CLLMD ectronically ElectronicallyFiled 10/28/202213:07 / SERVICE / CV 22 964736 / Confirmation Nbr. 2689201 / CLAHJ PAU LLC ATiancns/cruw tfRAfeapn sttainoo ItMAwnas 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. Darwcd 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 OBRAUSIUC & PAU LLC ATTOSNKY3ATLAW SStWOfipai OcKi>«M.4