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02D01-2307-CT-000515 Filed: 7/21/2023 3:23 PM
Clerk
Allen Superior Court 1 Allen County, Indiana
BB
STATE OF INDIANA ) IN THE ALLEN COURT
) SS:
COUNTY OF ALLEN ) CAUSE NO.
LEANNE MASTEJ
VS.
JOSEPH RYNE and UNITED FARM
FAMILY MUTUAL INSURANCE COMPANY
COMPLAINT FOR DAMAGES
FIRST CAUSE OF ACTION
Comes now the plaintiff, Leanne Mastej, by counsel, Ken Nunn Law Office, and for
cause of action against the defendant, Joseph Ryne, alleges and says:
1. That on or about June 24, 2023, the defendant, Joseph Ryne, negligently drove
his vehicle, causing his vehicle to strike the vehicle driven by the plaintiff, Leanne Mastej.
2. That said collision occurred within the boundaries of Allen County, State of
Indiana.
3. That the plaintiff received permanent injuries as a result of the defendant's
negligence.
4. That the plaintiff has incurred medical expenses, lost wages, property damage
including, but not limited to, diminished value, and other special expenses in an amount to be
proven at the trial of this cause, and will incur future medical expenses, lost wages and other
special expenses, as a direct and proximate result of defendant's negligence.
WHEREFORE, the plaintiff demands judgment against the defendant for permanent
injuries in a reasonable amount to be determined at the trial of this cause, for medical expenses,
lost wages, property damage including, but not limited to, diminished value, and other special
expenses, for future medical expenses, lost wages and other special expenses, court costs, and
all other proper relief in the premises.
-2-
SECOND CAUSE OF ACTION
Comes now the plaintiff, Leanne Mastej, by counsel, Ken Nunn Law Office, and for
cause of action against the defendant, United Farm Family Mutual Insurance Company, alleges
and says:
1. That she incorporates by reference all paragraphs of the First Cause of Action as
set out above.
2. That at the time of the collision, plaintiff was insured by defendant under an
uninsured/underinsured Motorist Coverage Endorsement, Policy No. 0009366699.
3. That plaintiff is making a claim for uninsured/underinsurance coverage in order
to be fully compensated for her injuries and damages suffered in said automobile accident,
which injuries and damages may exceed the amount of defendant’s policy limits.
4. That plaintiff has been injured and damaged in an amount to be proved at the trial
of this cause.
WHEREFORE, the plaintiff demands judgment against the defendant for permanent
injuries in a reasonable amount to be determined at the trial of this cause, for medical expenses,
lost wages, property damage including, but not limited to, diminished value, and other special
expenses, for future medical expenses, lost wages, and other special expenses, court costs, and
all other proper relief in the premises.
KEN NUNN LAW OFFICE
BY: s/ Nathan D. Foushee
Nathan D. Foushee, #24885-49
KEN NUNN LAW OFFICE
104 South Franklin Road
Bloomington, IN 47404
Phone: (812) 332-9451
Fax: (812) 331-5321
E-mail: nathanf@kennunn.com
-3-
REQUEST FOR TRIAL BY JURY
Comes now the plaintiff, by counsel, Ken Nunn Law Office, and requests that this
matter be tried by jury pursuant to Trial Rule 38.
KEN NUNN LAW OFFICE
BY: s/ Nathan D. Foushee
Nathan D. Foushee, #24885-49
KEN NUNN LAW OFFICE
104 South Franklin Road
Bloomington, IN 47404
Phone: (812) 332-9451
Fax: (812) 331-5321
E-mail: nathanf@kennunn.com
Nathan D. Foushee, #24885-49
Ken Nunn Law Office
104 South Franklin Road
Bloomington, IN 47404
Telephone: 812-332-9451
Fax Number: 812-331-5321
Attorney for Plaintiff
Preview
02D01-2307-CT-000515 Filed: 7/21/2023 3:23 PM Clerk Allen Superior Court 1 Allen County, Indiana BB STATE OF INDIANA ) IN THE ALLEN COURT ) SS: COUNTY OF ALLEN ) CAUSE NO. LEANNE MASTEJ VS. JOSEPH RYNE and UNITED FARM FAMILY MUTUAL INSURANCE COMPANY COMPLAINT FOR DAMAGES FIRST CAUSE OF ACTION Comes now the plaintiff, Leanne Mastej, by counsel, Ken Nunn Law Office, and for cause of action against the defendant, Joseph Ryne, alleges and says: 1. That on or about June 24, 2023, the defendant, Joseph Ryne, negligently drove his vehicle, causing his vehicle to strike the vehicle driven by the plaintiff, Leanne Mastej. 2. That said collision occurred within the boundaries of Allen County, State of Indiana. 3. That the plaintiff received permanent injuries as a result of the defendant's negligence. 4. That the plaintiff has incurred medical expenses, lost wages, property damage including, but not limited to, diminished value, and other special expenses in an amount to be proven at the trial of this cause, and will incur future medical expenses, lost wages and other special expenses, as a direct and proximate result of defendant's negligence. WHEREFORE, the plaintiff demands judgment against the defendant for permanent injuries in a reasonable amount to be determined at the trial of this cause, for medical expenses, lost wages, property damage including, but not limited to, diminished value, and other special expenses, for future medical expenses, lost wages and other special expenses, court costs, and all other proper relief in the premises. -2- SECOND CAUSE OF ACTION Comes now the plaintiff, Leanne Mastej, by counsel, Ken Nunn Law Office, and for cause of action against the defendant, United Farm Family Mutual Insurance Company, alleges and says: 1. That she incorporates by reference all paragraphs of the First Cause of Action as set out above. 2. That at the time of the collision, plaintiff was insured by defendant under an uninsured/underinsured Motorist Coverage Endorsement, Policy No. 0009366699. 3. That plaintiff is making a claim for uninsured/underinsurance coverage in order to be fully compensated for her injuries and damages suffered in said automobile accident, which injuries and damages may exceed the amount of defendant’s policy limits. 4. That plaintiff has been injured and damaged in an amount to be proved at the trial of this cause. WHEREFORE, the plaintiff demands judgment against the defendant for permanent injuries in a reasonable amount to be determined at the trial of this cause, for medical expenses, lost wages, property damage including, but not limited to, diminished value, and other special expenses, for future medical expenses, lost wages, and other special expenses, court costs, and all other proper relief in the premises. KEN NUNN LAW OFFICE BY: s/ Nathan D. Foushee Nathan D. Foushee, #24885-49 KEN NUNN LAW OFFICE 104 South Franklin Road Bloomington, IN 47404 Phone: (812) 332-9451 Fax: (812) 331-5321 E-mail: nathanf@kennunn.com -3- REQUEST FOR TRIAL BY JURY Comes now the plaintiff, by counsel, Ken Nunn Law Office, and requests that this matter be tried by jury pursuant to Trial Rule 38. KEN NUNN LAW OFFICE BY: s/ Nathan D. Foushee Nathan D. Foushee, #24885-49 KEN NUNN LAW OFFICE 104 South Franklin Road Bloomington, IN 47404 Phone: (812) 332-9451 Fax: (812) 331-5321 E-mail: nathanf@kennunn.com Nathan D. Foushee, #24885-49 Ken Nunn Law Office 104 South Franklin Road Bloomington, IN 47404 Telephone: 812-332-9451 Fax Number: 812-331-5321 Attorney for Plaintiff