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02D01-2312-CT-000866 Filed: 12/19/2023 12:08 PM
lerk
Allen Superior Court 1 Allen County, Indiana
Js
STATE OF INDIANA _ ) IN THE ALLEN SUPERIOR COURT
) SS:
COUNTY OF ALLEN ) CAUSE NO.
MANDI SUTORIUS,
Plaintiff,
vs.
JARED DYER and MIDWEST
GREEN LAWN CARE &
LANDSCAPING LLC,
Defendant.
COMPLAINT FOR DAMAGES
COUNT |
Plaintiff, Mandi Sutorius, for her claim for relief states:
i On August 4, 2022, Plaintiff, Mandi Sutorius, was driving a
vehicle north, in the right lane, on Coldwater Road, in Fort Wayne, Allen County,
Indiana, when her vehicle was struck by a vehicle also traveling north in the left
lane on Coldwater Road attempting a right-hand tum into a private drive, which
was being driven by Defendant, Jared Dyer, while in the course and scope of his
agency and/or employment with Defendant, Midwest Green Lawn Care &
Landscaping LLC.
Page 1 of 3
2 The collision was responsibly caused by the carelessness and
negligence of Defendant, Jared Dyer, in the operation of his vehicle for failing to
maintain and keep a reasonable and proper lookout, failing to maintain control of
his vehicle and improper turning, in violation of I.C. §9-21-8-21.
3 Defendant, Midwest Green Lawn Care & Landscaping, is vicariously
liable for the careless and negligent acts of its agent and/or employee, Defendant,
Jared Dyer, while in the course and scope of his agency and/or employment.
4 As a result of the collision, Plaintiff, Mandi Sutorius, sustained
physical injuries, which are permanent, and suffered and continues to suffer
ongoing physical pain.
5 As a further result of the collision, Plaintiff, Mandi Sutorius,
incurred hospital and medical expenses, lost wages and may incur such expenses
and losses in the future, as well as the loss of a whole and useful life,
WHEREFORE, Plaintiff, Mandi Sutorius, demands judgment against
Defendant, Jared Dyer, in an amount that will reasonably compensate her for the
injuries and damages sustained, for the costs of this action and for all other just and
proper relief in the premises and for trial by jury.
Page 2 of 3
Tom Blackburn (2761-71)
Attorney for Plaintiff
BLACKBURN ROMEY
4203 W. Jefferson Blvd.
Fort Wayne, IN 46804
Telephone: (260) 422-4400
Page 3 of 3
Preview
02D01-2312-CT-000866 Filed: 12/19/2023 12:08 PM lerk Allen Superior Court 1 Allen County, Indiana Js STATE OF INDIANA _ ) IN THE ALLEN SUPERIOR COURT ) SS: COUNTY OF ALLEN ) CAUSE NO. MANDI SUTORIUS, Plaintiff, vs. JARED DYER and MIDWEST GREEN LAWN CARE & LANDSCAPING LLC, Defendant. COMPLAINT FOR DAMAGES COUNT | Plaintiff, Mandi Sutorius, for her claim for relief states: i On August 4, 2022, Plaintiff, Mandi Sutorius, was driving a vehicle north, in the right lane, on Coldwater Road, in Fort Wayne, Allen County, Indiana, when her vehicle was struck by a vehicle also traveling north in the left lane on Coldwater Road attempting a right-hand tum into a private drive, which was being driven by Defendant, Jared Dyer, while in the course and scope of his agency and/or employment with Defendant, Midwest Green Lawn Care & Landscaping LLC. Page 1 of 3 2 The collision was responsibly caused by the carelessness and negligence of Defendant, Jared Dyer, in the operation of his vehicle for failing to maintain and keep a reasonable and proper lookout, failing to maintain control of his vehicle and improper turning, in violation of I.C. §9-21-8-21. 3 Defendant, Midwest Green Lawn Care & Landscaping, is vicariously liable for the careless and negligent acts of its agent and/or employee, Defendant, Jared Dyer, while in the course and scope of his agency and/or employment. 4 As a result of the collision, Plaintiff, Mandi Sutorius, sustained physical injuries, which are permanent, and suffered and continues to suffer ongoing physical pain. 5 As a further result of the collision, Plaintiff, Mandi Sutorius, incurred hospital and medical expenses, lost wages and may incur such expenses and losses in the future, as well as the loss of a whole and useful life, WHEREFORE, Plaintiff, Mandi Sutorius, demands judgment against Defendant, Jared Dyer, in an amount that will reasonably compensate her for the injuries and damages sustained, for the costs of this action and for all other just and proper relief in the premises and for trial by jury. Page 2 of 3 Tom Blackburn (2761-71) Attorney for Plaintiff BLACKBURN ROMEY 4203 W. Jefferson Blvd. Fort Wayne, IN 46804 Telephone: (260) 422-4400 Page 3 of 3