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ELECTRONICALLY FILED
Garland County Circuit Court
Kristie Womble-Hughes , Circuit Clerk
2024-Apr-18 17:14:15
26CV-24-468
C18ED01 : 5 Pages
IN THE CIRCUIT COURT OF GARLAND COUNTY
CIVIL DIVISION
KAYLA NEIGHBORS,
Individually, and as Parent and
Natural Guardian of G.N., A MINOR
And N.N., A MINOR PLAINTIFF
v. CASE NO. ________
JAMES CRIDDLE DEFENDANT
COMPLAINT
Comes now the Plaintiff, Kayla Neighbors, Individually, and as parent and natural guardian
of G.N., a minor, and N.N., a minor, by and through her attorneys, the Minton Law Firm, and for
her Complaint in negligence against the Defendant, James Cribble, and states:
JURISDICTIONAL STATEMENT
1. That the Plaintiff, Kayla Neighbors, and her minor children, G.N., and N.N.
(“Plaintiff”), are residents of Garland County.
2. That the Defendant, James Cribble (“Cribble”), is an individual resident of Hot
Spring County, Arkansas.
3. That the facts giving rise to this cause of action occurred within the three years last
past.
4. That the events herein occurred in Hot Springs, Garland County.
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5. That jurisdiction and venue are proper in this Court pursuant to Ark. Code Ann.
§16-13-201 and §16-60-112 over the parties and subject matter of this cause of action.
FACTUAL ALLEGATIONS
6. Plaintiffs restate and incorporate all paragraphs herein.
7. On or about June 10, 2023, at approximately 1:16 p.m.., the Plaintiff, Kayla
Neighbors, was operating her 2009 Chevrolet in a safe and prudent manner with G.N. and N.N. as
passengers, traveling southbound on Fox Pass Cutoff, stopped at the stop sign at its intersection
with Park Avenue.
8. At the same time and place, the Defendant, Criddle, was operating his 2004 Nissan
Titan traveling the same direction on Fox Pass Cutoff directly behind Neighbors.
9. As Criddle was approaching the intersection, he failed to stop or slow, and crashed
into the rear of Neighbors’ vehicle, thereby causing a violent collision which is the proximate
cause of Plaintiffs’ injuries and damages as more fully set forth herein below.
NEGLIGENCE
10. Plaintiff restates and incorporates all paragraphs herein.
11. Criddle owed a duty of care to Plaintiffs and others on the road.
12. Criddle breached that duty of care.
13. Said negligence includes the following acts and omissions, including, but not
limited, to the following:
a. Failing to keep a proper lookout;
b. Failing to keep the vehicle he was driving under control;
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c. Driving at an excess rate of speed under the circumstances;
d. Distracted driving;
e. Inattentive driving;
f. Careless and prohibited driving;
g. Reckless driving; and
h. Otherwise failing to act as a reasonably careful person would do under the
circumstances.
14. As a proximate result of the above negligence, the Plaintiff and her minor children
sustained injuries and compensatory damages more fully set out herein below.
DAMAGES
15. Plaintiff restates and incorporates all paragraphs herein.
16. As a result of the Defendant’s negligence, the Plaintiff, individually, has sustained
injuries and damages, including, but not limited to:
a. The nature, duration, and permanency of her injuries;
b. The reasonable expenses of any necessary medical care, treatment and services
received, including expenses necessarily incurred in securing such care, treatment,
or services; and the present value of such expense reasonably certain to be required
in the future;
c. Any pain and suffering and mental anguish experienced in the past and reasonably
certain to be experienced in the future;
d. Lost income and time off from work; and
e. Other consequential damages.
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17. On behalf of N.N., a minor, the Plaintiff claims:
a. The nature, duration, and permanency of her injuries;
b. The reasonable expenses of any necessary medical care, treatment and services
received, including expenses necessarily incurred in securing such care, treatment,
or services; and the present value of such expense reasonably certain to be required
in the future;
c. Any pain and suffering and mental anguish experienced in the past and reasonably
certain to be experienced in the future;
18. On behalf of G.N., a minor, the Plaintiff claims:
a. The nature, duration, and permanency of his injuries;
b. The reasonable expenses of any necessary medical care, treatment and services
received, including expenses necessarily incurred in securing such care, treatment,
or services; and the present value of such expense reasonably certain to be required
in the future;
c. Any pain and suffering and mental anguish experienced in the past and reasonably
certain to be experienced in the future.
19. Plaintiff demands a trial by jury.
20. Plaintiff reserves the right to amend this Complaint pending further discovery.
WHEREFORE, the Plaintiffs, Kayla Neighbors, G.N., and N.N., pray for judgment
against Defendant James Criddle for an amount of money to adequate to compensate her and the
minor children for the damages they have sustained, but less than the amount required for Federal
Court jurisdiction in diversity of citizenship cases. Plaintiff further prays for her costs, interest,
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and all other proper relief to which she may be entitled. Plaintiff further prays that she be granted
a jury trial.
Respectfully submitted,
MINTON LAW FIRM
2610 Salem Road
Benton, AR 72019
(501) 794-0001 Telephone
(501) 274-0222 Facsimile
By: /s/ J. Daniel Hall
J. Daniel Hall
Arkansas Bar No. 2021204
Daniel@JustinMintonLaw.com
M. Justin Minton
Justin@JustinMintonLaw.com
Arkansas Bar No. 2009-112
Counsel for Plaintiffs
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Preview
ELECTRONICALLY FILED Garland County Circuit Court Kristie Womble-Hughes , Circuit Clerk 2024-Apr-18 17:14:15 26CV-24-468 C18ED01 : 5 Pages IN THE CIRCUIT COURT OF GARLAND COUNTY CIVIL DIVISION KAYLA NEIGHBORS, Individually, and as Parent and Natural Guardian of G.N., A MINOR And N.N., A MINOR PLAINTIFF v. CASE NO. ________ JAMES CRIDDLE DEFENDANT COMPLAINT Comes now the Plaintiff, Kayla Neighbors, Individually, and as parent and natural guardian of G.N., a minor, and N.N., a minor, by and through her attorneys, the Minton Law Firm, and for her Complaint in negligence against the Defendant, James Cribble, and states: JURISDICTIONAL STATEMENT 1. That the Plaintiff, Kayla Neighbors, and her minor children, G.N., and N.N. (“Plaintiff”), are residents of Garland County. 2. That the Defendant, James Cribble (“Cribble”), is an individual resident of Hot Spring County, Arkansas. 3. That the facts giving rise to this cause of action occurred within the three years last past. 4. That the events herein occurred in Hot Springs, Garland County. 1 5. That jurisdiction and venue are proper in this Court pursuant to Ark. Code Ann. §16-13-201 and §16-60-112 over the parties and subject matter of this cause of action. FACTUAL ALLEGATIONS 6. Plaintiffs restate and incorporate all paragraphs herein. 7. On or about June 10, 2023, at approximately 1:16 p.m.., the Plaintiff, Kayla Neighbors, was operating her 2009 Chevrolet in a safe and prudent manner with G.N. and N.N. as passengers, traveling southbound on Fox Pass Cutoff, stopped at the stop sign at its intersection with Park Avenue. 8. At the same time and place, the Defendant, Criddle, was operating his 2004 Nissan Titan traveling the same direction on Fox Pass Cutoff directly behind Neighbors. 9. As Criddle was approaching the intersection, he failed to stop or slow, and crashed into the rear of Neighbors’ vehicle, thereby causing a violent collision which is the proximate cause of Plaintiffs’ injuries and damages as more fully set forth herein below. NEGLIGENCE 10. Plaintiff restates and incorporates all paragraphs herein. 11. Criddle owed a duty of care to Plaintiffs and others on the road. 12. Criddle breached that duty of care. 13. Said negligence includes the following acts and omissions, including, but not limited, to the following: a. Failing to keep a proper lookout; b. Failing to keep the vehicle he was driving under control; 2 c. Driving at an excess rate of speed under the circumstances; d. Distracted driving; e. Inattentive driving; f. Careless and prohibited driving; g. Reckless driving; and h. Otherwise failing to act as a reasonably careful person would do under the circumstances. 14. As a proximate result of the above negligence, the Plaintiff and her minor children sustained injuries and compensatory damages more fully set out herein below. DAMAGES 15. Plaintiff restates and incorporates all paragraphs herein. 16. As a result of the Defendant’s negligence, the Plaintiff, individually, has sustained injuries and damages, including, but not limited to: a. The nature, duration, and permanency of her injuries; b. The reasonable expenses of any necessary medical care, treatment and services received, including expenses necessarily incurred in securing such care, treatment, or services; and the present value of such expense reasonably certain to be required in the future; c. Any pain and suffering and mental anguish experienced in the past and reasonably certain to be experienced in the future; d. Lost income and time off from work; and e. Other consequential damages. 3 17. On behalf of N.N., a minor, the Plaintiff claims: a. The nature, duration, and permanency of her injuries; b. The reasonable expenses of any necessary medical care, treatment and services received, including expenses necessarily incurred in securing such care, treatment, or services; and the present value of such expense reasonably certain to be required in the future; c. Any pain and suffering and mental anguish experienced in the past and reasonably certain to be experienced in the future; 18. On behalf of G.N., a minor, the Plaintiff claims: a. The nature, duration, and permanency of his injuries; b. The reasonable expenses of any necessary medical care, treatment and services received, including expenses necessarily incurred in securing such care, treatment, or services; and the present value of such expense reasonably certain to be required in the future; c. Any pain and suffering and mental anguish experienced in the past and reasonably certain to be experienced in the future. 19. Plaintiff demands a trial by jury. 20. Plaintiff reserves the right to amend this Complaint pending further discovery. WHEREFORE, the Plaintiffs, Kayla Neighbors, G.N., and N.N., pray for judgment against Defendant James Criddle for an amount of money to adequate to compensate her and the minor children for the damages they have sustained, but less than the amount required for Federal Court jurisdiction in diversity of citizenship cases. Plaintiff further prays for her costs, interest, 4 and all other proper relief to which she may be entitled. Plaintiff further prays that she be granted a jury trial. Respectfully submitted, MINTON LAW FIRM 2610 Salem Road Benton, AR 72019 (501) 794-0001 Telephone (501) 274-0222 Facsimile By: /s/ J. Daniel Hall J. Daniel Hall Arkansas Bar No. 2021204 Daniel@JustinMintonLaw.com M. Justin Minton Justin@JustinMintonLaw.com Arkansas Bar No. 2009-112 Counsel for Plaintiffs 5