Preview
ELECTRONICALLY FILED - 2023 Jan 11 2:29 PM - CHESTERFIELD - COMMON PLEAS - CASE#2023CP1300014
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) FOR THE TWELFTH JUDICIAL CIRCUIT
COUNTY OF CHESTERFIELD )
)
Samantha Zgombic, )
Emma Simons, ) SUMMONS
Emily Shupe, ) (JURY TRIAL DEMANDED)
Antonia Stivaletti )
Plaintiffs, )
)
VS. )
)
Ryan Ziekiell Jackson,
Defendant
)
YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action,
a copy of which is served upon you, and to serve a copy of your Answer to said Complaint on the
subscriber at their office at 402 Church Street, Georgetown, South Carolina 29440, within thirty
(30) days of service thereof, exclusive of the day of said service; and if you fail to answer, appear
or otherwise plead within the time aforesaid, the Plaintiffs in this action will apply to the Court for
a judgement by default for the relief demanded in this complaint and will further apply to the Court
to have you placed in default.
s/ Madison Harte
Madison Harte
Parham Law Firm, LLC
402 Church Street
Georgetown, South Carolina 29440
Telephone: (843) 278-0229
Facsimile: (843) 277-0655
Attorney for Plaintiff
January 9, 2023
Georgetown, South Carolina
ELECTRONICALLY FILED - 2023 Jan 11 2:29 PM - CHESTERFIELD - COMMON PLEAS - CASE#2023CP1300014
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) FOR THE TWELFTH JUDICIAL CIRCUIT
COUNTY OF CHESTERFIELD )
)
Samantha Zgombic, )
Emma Simons, ) COMPLAINT
Emily Shupe, ) (PERSONAL INJURY)
Antonia Stivaletti, ) (JURY TRIAL DEMANDED)
Plaintiffs, )
)
VS. )
)
Ryan Ziekiell Jackson,
Defendant
)
COMES NOW Plaintiffs, Samantha Zgombic, Emma Simons, Emily Shupe, and Antonia
Stivaletti (hereinafter referred to as “Plaintiffs”) and sues the Defendants above-named and alleges
as follows:
1. Plaintiffs are citizens and residents of the County of Union, State of North Carolina.
2. Upon information and belief, Defendant, Ryan Ziekiell Jackson (hereinafter referred to as
“Defendant”), is a citizen and resident of the County of Chesterfield, State of South
Carolina, and at the time of the of the hereinafter mentioned occurrence was the owner and
operator of a 2013 Chevrolet truck.
3. That the substantial acts and omissions alleged herein occurred in Chesterfield County,
South Carolina.
4. On or about August 10 16, 2021, at approximately 6:00 P.M., Plaintiffs were driving and
passengers in a 2016 Honda Pilot. Plaintiff was traveling north on Highway 151, in the
County of Chesterfield, State of South Carolina. Plaintiffs were in the right lane of travel
ELECTRONICALLY FILED - 2023 Jan 11 2:29 PM - CHESTERFIELD - COMMON PLEAS - CASE#2023CP1300014
on their way home from a competitive dance competition to Waxhaw, North Carolina.
Defendant was travelling east on SEC 172 when he disregarded a stop sign and drove
directly into the path of Plaintiff’s vehicle. Plaintiff applied maximum break pressure in
order to avoid colliding with Defendant who had driven through a stop sign without
stopping and pulled out in front of them.
5. Defendant disregarded a stop sign and pulled out directly in front of Plaintiff’s vehicle.
6. As a result of the collision, Plaintiffs suffered the following injuries and damages:
a. extensive pain, mental anguish, suffering and discomfort;
b. disability for a period of time, past and future;
c. money spent for medical care and treatment, past, present and future;
d. inability to carry on normal activities;
e. permanent injuries and partial disability;
f. emotional trauma and distress; and
g. loss of enjoyment of life.
FOR A FIRST CAUSE OF ACTION AGAINST DEFENDANTS
(NEGLIGENCE)
7. Plaintiffs reallege and incorporate by reference all those facts and allegations in paragraphs
1 through 5 above and further alleges:
8. At the above time and location and at all times pertinent hereto, Defendant was negligent
in one or more of the following in that they:
a. failed to operate his motor vehicle under proper control;
b. failed to operate his vehicle in a safe and lawful manner;
ELECTRONICALLY FILED - 2023 Jan 11 2:29 PM - CHESTERFIELD - COMMON PLEAS - CASE#2023CP1300014
c. failed to keep a proper lookout for motor vehicles traveling in the same roads and
highways, and especially the vehicle with which he collided;
d. was traveling too fast for conditions;
e. failed to observe the other vehicle involved in the accident and avoid the collision
described herein, when it was at all times hereto in plain and unobstructed view;
f. failed to utilize his brakes;
g. failed to exercise reasonable care in the operation of his motor vehicle under the
circumstances then and there existing, and operating his motor vehicle in a careless
and grossly negligent manner with reckless disregard for the safety of others;
h. failed to use the degree of care and caution that a reasonable and prudent person
would have used under the circumstances then and there prevailing—all of which
were a direct and proximate cause of the damages and injuries suffered by Plaintiff
herein, said acts being in violation of the statutory and common laws of the State
of South Carolina; and
i. in other respects not now known to Plaintiff but which may become known prior to
or at the time of trial.
9. Defendant’s careless, negligent, willful, wanton, reckless and unlawful acts were the direct
and proximate cause of the collision and resulting injuries and damages to Plaintiffs.
10. Plaintiffs believe the Defendant is liable to her for actual and punitive damages.
WHEREFORE, the Plaintiff prays for judgment against Defendant in excess of Five Hundred
Thousand ($500,000.00) Dollars, for actual and punitive damages in an appropriate amount to be
determined at trial, the costs of this action, and for such other and further relief as the Court may
deem just and proper.
ELECTRONICALLY FILED - 2023 Jan 11 2:29 PM - CHESTERFIELD - COMMON PLEAS - CASE#2023CP1300014
s/ Madison Harte
Madison Harte
SC Bar #: 102887
Parham Law Firm, LLC
402 Church Street
Georgetown, South Carolina 29440
Telephone: (843) 278-0229
Facsimile: (843) 277-0655
Attorney for Plaintiff
January 9, 2023
Georgetown, South Carolina
Preview
ELECTRONICALLY FILED - 2023 Jan 11 2:29 PM - CHESTERFIELD - COMMON PLEAS - CASE#2023CP1300014 STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS ) FOR THE TWELFTH JUDICIAL CIRCUIT COUNTY OF CHESTERFIELD ) ) Samantha Zgombic, ) Emma Simons, ) SUMMONS Emily Shupe, ) (JURY TRIAL DEMANDED) Antonia Stivaletti ) Plaintiffs, ) ) VS. ) ) Ryan Ziekiell Jackson, Defendant ) YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, a copy of which is served upon you, and to serve a copy of your Answer to said Complaint on the subscriber at their office at 402 Church Street, Georgetown, South Carolina 29440, within thirty (30) days of service thereof, exclusive of the day of said service; and if you fail to answer, appear or otherwise plead within the time aforesaid, the Plaintiffs in this action will apply to the Court for a judgement by default for the relief demanded in this complaint and will further apply to the Court to have you placed in default. s/ Madison Harte Madison Harte Parham Law Firm, LLC 402 Church Street Georgetown, South Carolina 29440 Telephone: (843) 278-0229 Facsimile: (843) 277-0655 Attorney for Plaintiff January 9, 2023 Georgetown, South Carolina ELECTRONICALLY FILED - 2023 Jan 11 2:29 PM - CHESTERFIELD - COMMON PLEAS - CASE#2023CP1300014 STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS ) FOR THE TWELFTH JUDICIAL CIRCUIT COUNTY OF CHESTERFIELD ) ) Samantha Zgombic, ) Emma Simons, ) COMPLAINT Emily Shupe, ) (PERSONAL INJURY) Antonia Stivaletti, ) (JURY TRIAL DEMANDED) Plaintiffs, ) ) VS. ) ) Ryan Ziekiell Jackson, Defendant ) COMES NOW Plaintiffs, Samantha Zgombic, Emma Simons, Emily Shupe, and Antonia Stivaletti (hereinafter referred to as “Plaintiffs”) and sues the Defendants above-named and alleges as follows: 1. Plaintiffs are citizens and residents of the County of Union, State of North Carolina. 2. Upon information and belief, Defendant, Ryan Ziekiell Jackson (hereinafter referred to as “Defendant”), is a citizen and resident of the County of Chesterfield, State of South Carolina, and at the time of the of the hereinafter mentioned occurrence was the owner and operator of a 2013 Chevrolet truck. 3. That the substantial acts and omissions alleged herein occurred in Chesterfield County, South Carolina. 4. On or about August 10 16, 2021, at approximately 6:00 P.M., Plaintiffs were driving and passengers in a 2016 Honda Pilot. Plaintiff was traveling north on Highway 151, in the County of Chesterfield, State of South Carolina. Plaintiffs were in the right lane of travel ELECTRONICALLY FILED - 2023 Jan 11 2:29 PM - CHESTERFIELD - COMMON PLEAS - CASE#2023CP1300014 on their way home from a competitive dance competition to Waxhaw, North Carolina. Defendant was travelling east on SEC 172 when he disregarded a stop sign and drove directly into the path of Plaintiff’s vehicle. Plaintiff applied maximum break pressure in order to avoid colliding with Defendant who had driven through a stop sign without stopping and pulled out in front of them. 5. Defendant disregarded a stop sign and pulled out directly in front of Plaintiff’s vehicle. 6. As a result of the collision, Plaintiffs suffered the following injuries and damages: a. extensive pain, mental anguish, suffering and discomfort; b. disability for a period of time, past and future; c. money spent for medical care and treatment, past, present and future; d. inability to carry on normal activities; e. permanent injuries and partial disability; f. emotional trauma and distress; and g. loss of enjoyment of life. FOR A FIRST CAUSE OF ACTION AGAINST DEFENDANTS (NEGLIGENCE) 7. Plaintiffs reallege and incorporate by reference all those facts and allegations in paragraphs 1 through 5 above and further alleges: 8. At the above time and location and at all times pertinent hereto, Defendant was negligent in one or more of the following in that they: a. failed to operate his motor vehicle under proper control; b. failed to operate his vehicle in a safe and lawful manner; ELECTRONICALLY FILED - 2023 Jan 11 2:29 PM - CHESTERFIELD - COMMON PLEAS - CASE#2023CP1300014 c. failed to keep a proper lookout for motor vehicles traveling in the same roads and highways, and especially the vehicle with which he collided; d. was traveling too fast for conditions; e. failed to observe the other vehicle involved in the accident and avoid the collision described herein, when it was at all times hereto in plain and unobstructed view; f. failed to utilize his brakes; g. failed to exercise reasonable care in the operation of his motor vehicle under the circumstances then and there existing, and operating his motor vehicle in a careless and grossly negligent manner with reckless disregard for the safety of others; h. failed to use the degree of care and caution that a reasonable and prudent person would have used under the circumstances then and there prevailing—all of which were a direct and proximate cause of the damages and injuries suffered by Plaintiff herein, said acts being in violation of the statutory and common laws of the State of South Carolina; and i. in other respects not now known to Plaintiff but which may become known prior to or at the time of trial. 9. Defendant’s careless, negligent, willful, wanton, reckless and unlawful acts were the direct and proximate cause of the collision and resulting injuries and damages to Plaintiffs. 10. Plaintiffs believe the Defendant is liable to her for actual and punitive damages. WHEREFORE, the Plaintiff prays for judgment against Defendant in excess of Five Hundred Thousand ($500,000.00) Dollars, for actual and punitive damages in an appropriate amount to be determined at trial, the costs of this action, and for such other and further relief as the Court may deem just and proper. ELECTRONICALLY FILED - 2023 Jan 11 2:29 PM - CHESTERFIELD - COMMON PLEAS - CASE#2023CP1300014 s/ Madison Harte Madison Harte SC Bar #: 102887 Parham Law Firm, LLC 402 Church Street Georgetown, South Carolina 29440 Telephone: (843) 278-0229 Facsimile: (843) 277-0655 Attorney for Plaintiff January 9, 2023 Georgetown, South Carolina