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64D01-2308-CT-007848 Filed: 8/28/2023 1:09 PM
Clerk
Porter Superior Court 1 Porter County, Indiana
STATE OF INDIANA ) IN THE PORTER SUPERIOR COURT
)SS:
COUNTY OF PORTER )
NATHAN GOODFELLOW and )
CHRISTINE HERNANDEZ )
)
Plaintiffs, )
)
vs. ) CAUSE NO.
)
KARIN CANNON )
)
Defendant. )
COMPLAINT
COMES NOW Plaintiffs, Nathan Goodfellow and Christine Hernandez, by counsel, David
A. Wilson, Megan L. Craig and John Craig, and for Plaintiffs’ Complaint against Defendant, Karin
Cannon, states as follows:
1. That presently and at the time of the incident described herein, Plaintiff Nathan Goodfellow
is a resident of Porter County, Indiana.
2. That presently and at the time of the incident described herein, Plaintiff Christine
Hernandez is a resident of Porter County, Indiana.
3. That presently and at the time of the incident described herein, Defendant Karin Cannon is
a resident of Porter County, Indiana.
4. That on August 13, 2023, Plaintiff Nathan Goodfellow was operating a Yamaha
motorcycle and traveling eastbound on W.100 S. in Valparaiso, Indiana.
5. That at the same time, Defendant Karin Cannon was operating a vehicle and traveling
westbound on W. 100 South, in Valparaiso, Indiana.
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6. That Defendant Cannon initiated a left-hand turn to travel on Springwood Drive in the
Springwood Subdivision in Valparaiso, Indiana, turning directly into the lane where
Nathan Goodfellow was operating his motorcycle, and then stopping in said lane.
7. That the collision between the two vehicles caused Plaintiffs Nathan Goodfellow and
Christine Hernandez to be ejected from the motorcycle.
8. On August 13, 2023, Defendant Cannon was negligent, careless and/or reckless by
committing the following acts and/or omissions:
a. Failure to maintain a proper lookout;
b. Failure to reasonably control her vehicle;
c. Failing to yield the right of way
d. Initiating a turn when such movement could not be performed with reasonable
safety;
e. Failure to act as a reasonably prudent driver would have acted under the same or
similar conditions.
9. That as a direct and proximate result of Defendant’s negligence, the Plaintiff Nathan
Goodfellow, there and then sustained physical injuries, and mental and emotional injuries,
some of which injuries are permanent, was and will be further hindered and prevented in
whole or in part from attending to the usual duties and affairs, has incurred medical bills
for his care and treatment, and incurred other losses of a pecuniary nature.
10. That as a direct and proximate result of Defendant’s negligence, the Plaintiff, Christine
Hernandez, there and then sustained physical injuries, and mental and emotional injuries,
some of which injuries are permanent, was and will be further hindered and prevented in
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whole or in part from attending to the usual duties and affairs, has incurred medical bills
for his care and treatment, and incurred other losses of a pecuniary nature.
WHEREFORE the Plaintiffs, Nathan Goodfellow and Christine Hernandez, pray for
judgment against the Defendant, Karin Cannon, and seeks compensatory damages which will
reasonably compensate Plaintiffs, plus costs, prejudgment interest and all other just and proper
relief in the premises.
Respectfully submitted,
______________ ___ _/s/ Megan L. Craig_______________
David A. Wilson (#19629-64) Megan L. Craig (#23184-49)
Wilson & Novak, P.C., Craig & Craig, LLC
200 W. 80th Place, 400 E. 86th Ave.
Merrillville, IN 46410 Merrillville, IN 46410
One of the Attorneys for Plaintiffs One of the Attorneys for Plaintiffs
_/s/ John R. Craig_______________
John R. Craig (#22320-45)
Craig & Craig, LLC
400 E. 86th Ave.
Merrillville, IN 46410
One of the Attorneys for Plaintiffs
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JURY DEMAND
Plaintiffs, Nathan Goodfellow and Christine Hernandez, by and through counsel, and
demands trial by jury on all issues contained herein.
Respectfully submitted,
______________ ___ _/s/ Megan L. Craig_______________
David A. Wilson (#19629-64) Megan L. Craig (#23184-49)
Wilson & Novak, P.C., Craig & Craig, LLC
200 W. 80th Place, 400 E. 86th Ave.
Merrillville, IN 46410 Merrillville, IN 46410
One of the Attorneys for Plaintiffs One of the Attorneys for Plaintiffs
_/s/ John R. Craig _______________
John R. Craig (#22320-45)
Craig & Craig, LLC
400 E. 86th Ave.
Merrillville, IN 46410
One of the Attorneys for Plaintiffs
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Preview
64D01-2308-CT-007848 Filed: 8/28/2023 1:09 PM Clerk Porter Superior Court 1 Porter County, Indiana STATE OF INDIANA ) IN THE PORTER SUPERIOR COURT )SS: COUNTY OF PORTER ) NATHAN GOODFELLOW and ) CHRISTINE HERNANDEZ ) ) Plaintiffs, ) ) vs. ) CAUSE NO. ) KARIN CANNON ) ) Defendant. ) COMPLAINT COMES NOW Plaintiffs, Nathan Goodfellow and Christine Hernandez, by counsel, David A. Wilson, Megan L. Craig and John Craig, and for Plaintiffs’ Complaint against Defendant, Karin Cannon, states as follows: 1. That presently and at the time of the incident described herein, Plaintiff Nathan Goodfellow is a resident of Porter County, Indiana. 2. That presently and at the time of the incident described herein, Plaintiff Christine Hernandez is a resident of Porter County, Indiana. 3. That presently and at the time of the incident described herein, Defendant Karin Cannon is a resident of Porter County, Indiana. 4. That on August 13, 2023, Plaintiff Nathan Goodfellow was operating a Yamaha motorcycle and traveling eastbound on W.100 S. in Valparaiso, Indiana. 5. That at the same time, Defendant Karin Cannon was operating a vehicle and traveling westbound on W. 100 South, in Valparaiso, Indiana. -1- 6. That Defendant Cannon initiated a left-hand turn to travel on Springwood Drive in the Springwood Subdivision in Valparaiso, Indiana, turning directly into the lane where Nathan Goodfellow was operating his motorcycle, and then stopping in said lane. 7. That the collision between the two vehicles caused Plaintiffs Nathan Goodfellow and Christine Hernandez to be ejected from the motorcycle. 8. On August 13, 2023, Defendant Cannon was negligent, careless and/or reckless by committing the following acts and/or omissions: a. Failure to maintain a proper lookout; b. Failure to reasonably control her vehicle; c. Failing to yield the right of way d. Initiating a turn when such movement could not be performed with reasonable safety; e. Failure to act as a reasonably prudent driver would have acted under the same or similar conditions. 9. That as a direct and proximate result of Defendant’s negligence, the Plaintiff Nathan Goodfellow, there and then sustained physical injuries, and mental and emotional injuries, some of which injuries are permanent, was and will be further hindered and prevented in whole or in part from attending to the usual duties and affairs, has incurred medical bills for his care and treatment, and incurred other losses of a pecuniary nature. 10. That as a direct and proximate result of Defendant’s negligence, the Plaintiff, Christine Hernandez, there and then sustained physical injuries, and mental and emotional injuries, some of which injuries are permanent, was and will be further hindered and prevented in -2- whole or in part from attending to the usual duties and affairs, has incurred medical bills for his care and treatment, and incurred other losses of a pecuniary nature. WHEREFORE the Plaintiffs, Nathan Goodfellow and Christine Hernandez, pray for judgment against the Defendant, Karin Cannon, and seeks compensatory damages which will reasonably compensate Plaintiffs, plus costs, prejudgment interest and all other just and proper relief in the premises. Respectfully submitted, ______________ ___ _/s/ Megan L. Craig_______________ David A. Wilson (#19629-64) Megan L. Craig (#23184-49) Wilson & Novak, P.C., Craig & Craig, LLC 200 W. 80th Place, 400 E. 86th Ave. Merrillville, IN 46410 Merrillville, IN 46410 One of the Attorneys for Plaintiffs One of the Attorneys for Plaintiffs _/s/ John R. Craig_______________ John R. Craig (#22320-45) Craig & Craig, LLC 400 E. 86th Ave. Merrillville, IN 46410 One of the Attorneys for Plaintiffs -3- JURY DEMAND Plaintiffs, Nathan Goodfellow and Christine Hernandez, by and through counsel, and demands trial by jury on all issues contained herein. Respectfully submitted, ______________ ___ _/s/ Megan L. Craig_______________ David A. Wilson (#19629-64) Megan L. Craig (#23184-49) Wilson & Novak, P.C., Craig & Craig, LLC 200 W. 80th Place, 400 E. 86th Ave. Merrillville, IN 46410 Merrillville, IN 46410 One of the Attorneys for Plaintiffs One of the Attorneys for Plaintiffs _/s/ John R. Craig _______________ John R. Craig (#22320-45) Craig & Craig, LLC 400 E. 86th Ave. Merrillville, IN 46410 One of the Attorneys for Plaintiffs -4-