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ELECTRONICALLY FILED - 2024 Apr 30 8:07 AM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002254
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) NINTH JUDICIAL CIRCUIT
COUNTY OF CHARLESTON )
) CASE NO.:
SHAVON WASHINGTON )
) CASE NO.: 2024-CP-10-_____________
)
Plaintiff, )
) SUMMONS
Vs. )
)
DERRICK LEVONE PHALO, )
)
Defendant. )
)
__________________________________ )
TO: THE DEFENDANT ABOVE-NAMED:
YOU ARE HEREBY SUMMONED and required to Answer the Complaint in this action, a copy
of which is herewith served upon you, and to serve a copy of your Answer to the said Complaint upon the
undersigned attorney, at 219 N Hwy 52, Unit P1, Moncks Corner, SC 29461, within thirty (30) days after
service hereof, exclusive of the day of service. If you fail to Answer the Complaint within that time,
judgment by default will be rendered against you for the relief demanded in the Complaint.
S/ Amber Daniels
Amber Daniels, Esq.
Bar No.: 103433
AMBER DANIELS LAW
219 N Hwy 52
Unit P1
Moncks Corner, SC 29461
843.952.9046 (T)
843.284.5627 (F)
amber@amberdanielslaw.com
April 30, 2024
Moncks Corner, South Carolina
ELECTRONICALLY FILED - 2024 Apr 30 8:07 AM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002254
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) NINTH JUDICIAL CIRCUIT
COUNTY OF CHARLESTON )
) CASE NO.: 2024-CP-10-_____________
SHAVON WASHINGTON )
)
Plaintiff, )
) COMPLAINT
Vs. ) (JURY TRIAL DEMANDED-
) AUTO-NEGLIGENCE)
DERRICK PHALO, )
)
Defendant. )
)
__________________________________ )
The Plaintiffs above named, complaining of the Defendant alleges and says:
1. That Plaintiff, Shavon Washington, is a resident and citizen of the State of South Carolina, County
of Berkeley.
2. That upon information and belief, Defendant Derrick Levone Phalo is a citizen and resident of the
State of Alabama, County of Mobile.
3. That on June 17, 2022, at approximately 4:25 P.M. Plaintiff was the restrained operator of a 2017
Ford sedan traveling northbound on Sam Rittenberg Blvd. in Charleston, South Carolina.
4. That on the aforesaid date, time and place, Defendant was the operator of a 2019 Chevy pickup
truck bearing an Alabama license tag #6741BH8, when by and through the negligence,
carelessness, recklessness, willfulness and wantonness of the Defendant, Defendant failed to apply
his brakes causing a rear-end collision with Plaintiff’s vehicle.
5. The collision with Defendant resulted in Plaintiff experiencing bodily injuries to their persons and
property damage to their vehicle.
FOR A FIRST CAUSE OF ACTION
NEGLIENCE
6. The negligence, carelessness, recklessness, willfulness and wantonness of the Defendant
consisted, among other things, of the following:
a. In failing to observe traffic laws of the highway as he traveled when Defendant knew or
should have known that this would inevitably cause the collision that occurred;
ELECTRONICALLY FILED - 2024 Apr 30 8:07 AM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002254
b. In failing to stop;
c. In failing to slow down;
d. In failing to apply his breaks properly;
e. In failing to keep a safe distance
f. In driving while distracted;
g. In driving while being inattentive;
h. In failing to keep a proper lookout for other vehicles;
i. In failing to take any precaution to prevent Plaintiff from being injured as a result of the
dangerous condition created by Defendant;
j. In failing to have and keep his vehicle under proper and reasonable control;
k. In failing to exercise that degree of care which a reasonably prudent person would have
exercised under the same or similar circumstances;
l. In such other and further particulars as the evidence in trial may show.
7. That by reason of an din consequence of the foregoing and as a direct and proximate result thereof,
Plaintiff Shavon Washington was struck in a sudden manner, resulting in multiple injuries to
Plaintiff’s body including injuries to her neck, back, shoulders, and other trauma requiring
treatment from physicians and other medical personnel, by reason of which Plaintiff has been
caused to expend great sums of monies and will in the future be required to expend further sums of
monies; and as a direct and proximate result of which she has suffered and will suffer pain and
mental anguish and has been prevented and will be prevented from engaged in normal activities,
including work, and she has been deprived of enjoyments of persons in like circumstances and she
has been otherwise damaged.
8. Defendant is liable for compensatory, consequential, actual, and punitive damages, as well as such
other relief as the Court may deem appropriate.
ELECTRONICALLY FILED - 2024 Apr 30 8:07 AM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002254
WHEREFORE, Plaintiffs pray for judgment against Defendant for such sums as willfully, fairly
and justly compensate Plaintiffs for actual damages and costs of this action, and for such punitive
damages that may be just and proper under the circumstances.
Respectfully submitted,
S/ Amber Daniels
Amber Daniels, Esq.
Bar No.: 103433
AMBER DANIELS LAW
219 N Hwy 52
Unit P1
Moncks Corner, SC 29461
843.952.9046 (T)
843.284.5627 (F)
amber@amberdanielslaw.com
April 30, 2024
Moncks Corner, South Carolina
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ELECTRONICALLY FILED - 2024 Apr 30 8:07 AM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002254 STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS ) NINTH JUDICIAL CIRCUIT COUNTY OF CHARLESTON ) ) CASE NO.: SHAVON WASHINGTON ) ) CASE NO.: 2024-CP-10-_____________ ) Plaintiff, ) ) SUMMONS Vs. ) ) DERRICK LEVONE PHALO, ) ) Defendant. ) ) __________________________________ ) TO: THE DEFENDANT ABOVE-NAMED: YOU ARE HEREBY SUMMONED and required to Answer the Complaint in this action, a copy of which is herewith served upon you, and to serve a copy of your Answer to the said Complaint upon the undersigned attorney, at 219 N Hwy 52, Unit P1, Moncks Corner, SC 29461, within thirty (30) days after service hereof, exclusive of the day of service. If you fail to Answer the Complaint within that time, judgment by default will be rendered against you for the relief demanded in the Complaint. S/ Amber Daniels Amber Daniels, Esq. Bar No.: 103433 AMBER DANIELS LAW 219 N Hwy 52 Unit P1 Moncks Corner, SC 29461 843.952.9046 (T) 843.284.5627 (F) amber@amberdanielslaw.com April 30, 2024 Moncks Corner, South Carolina ELECTRONICALLY FILED - 2024 Apr 30 8:07 AM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002254 STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS ) NINTH JUDICIAL CIRCUIT COUNTY OF CHARLESTON ) ) CASE NO.: 2024-CP-10-_____________ SHAVON WASHINGTON ) ) Plaintiff, ) ) COMPLAINT Vs. ) (JURY TRIAL DEMANDED- ) AUTO-NEGLIGENCE) DERRICK PHALO, ) ) Defendant. ) ) __________________________________ ) The Plaintiffs above named, complaining of the Defendant alleges and says: 1. That Plaintiff, Shavon Washington, is a resident and citizen of the State of South Carolina, County of Berkeley. 2. That upon information and belief, Defendant Derrick Levone Phalo is a citizen and resident of the State of Alabama, County of Mobile. 3. That on June 17, 2022, at approximately 4:25 P.M. Plaintiff was the restrained operator of a 2017 Ford sedan traveling northbound on Sam Rittenberg Blvd. in Charleston, South Carolina. 4. That on the aforesaid date, time and place, Defendant was the operator of a 2019 Chevy pickup truck bearing an Alabama license tag #6741BH8, when by and through the negligence, carelessness, recklessness, willfulness and wantonness of the Defendant, Defendant failed to apply his brakes causing a rear-end collision with Plaintiff’s vehicle. 5. The collision with Defendant resulted in Plaintiff experiencing bodily injuries to their persons and property damage to their vehicle. FOR A FIRST CAUSE OF ACTION NEGLIENCE 6. The negligence, carelessness, recklessness, willfulness and wantonness of the Defendant consisted, among other things, of the following: a. In failing to observe traffic laws of the highway as he traveled when Defendant knew or should have known that this would inevitably cause the collision that occurred; ELECTRONICALLY FILED - 2024 Apr 30 8:07 AM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002254 b. In failing to stop; c. In failing to slow down; d. In failing to apply his breaks properly; e. In failing to keep a safe distance f. In driving while distracted; g. In driving while being inattentive; h. In failing to keep a proper lookout for other vehicles; i. In failing to take any precaution to prevent Plaintiff from being injured as a result of the dangerous condition created by Defendant; j. In failing to have and keep his vehicle under proper and reasonable control; k. In failing to exercise that degree of care which a reasonably prudent person would have exercised under the same or similar circumstances; l. In such other and further particulars as the evidence in trial may show. 7. That by reason of an din consequence of the foregoing and as a direct and proximate result thereof, Plaintiff Shavon Washington was struck in a sudden manner, resulting in multiple injuries to Plaintiff’s body including injuries to her neck, back, shoulders, and other trauma requiring treatment from physicians and other medical personnel, by reason of which Plaintiff has been caused to expend great sums of monies and will in the future be required to expend further sums of monies; and as a direct and proximate result of which she has suffered and will suffer pain and mental anguish and has been prevented and will be prevented from engaged in normal activities, including work, and she has been deprived of enjoyments of persons in like circumstances and she has been otherwise damaged. 8. Defendant is liable for compensatory, consequential, actual, and punitive damages, as well as such other relief as the Court may deem appropriate. ELECTRONICALLY FILED - 2024 Apr 30 8:07 AM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002254 WHEREFORE, Plaintiffs pray for judgment against Defendant for such sums as willfully, fairly and justly compensate Plaintiffs for actual damages and costs of this action, and for such punitive damages that may be just and proper under the circumstances. Respectfully submitted, S/ Amber Daniels Amber Daniels, Esq. Bar No.: 103433 AMBER DANIELS LAW 219 N Hwy 52 Unit P1 Moncks Corner, SC 29461 843.952.9046 (T) 843.284.5627 (F) amber@amberdanielslaw.com April 30, 2024 Moncks Corner, South Carolina