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45D01-2406-CT-000771 Filed: 6/18/2024 1:28 PM
Clerk
Lake Superior Court, Civil Division 1 Lake County, Indiana
STATE OF INDIANA ) IN THE LAKE COURT
) SS:
COUNTY OF LAKE ) CAUSE NO.
DONNA HILL, KANDACE MARBERRY,
and KEVIN WASHINGTON
VS.
LATISHA THOMAS-STREETER and STATE FARM
MUTUAL AUTOMOBILE INSURANCE COMPANY
COMPLAINT FOR DAMAGES
FIRST CAUSE OF ACTION
Comes now the plaintiffs, Donna Hill, Kandace Marberry, and Kevin Washington, by
counsel, Ken Nunn Law Office, and for cause of action against the defendant, Latisha Thomas-
Streeter, alleges and says:
1. That on or about April 14, 2024, the defendant, Latisha Thomas-Streeter,
negligently drove her vehicle, causing her vehicle to strike the vehicle driven by the plaintiff,
Donna Hill, and in which plaintiffs, Kandace Marberry and Kevin Washington, were passengers.
2. That said collision occurred within the boundaries of Lake County, State of
Indiana.
3. That the plaintiffs received permanent injuries, pain, suffering, and anguish as a
result of the defendant's negligence.
4. That the plaintiffs have incurred medical expenses, lost wages, property damage
including, but not limited to, diminished value, and other special expenses in an amount to be
proven at the trial of this cause, and will incur future medical expenses, lost wages and other
special expenses, as a direct and proximate result of defendant's negligence.
WHEREFORE, the plaintiffs demand judgment against the defendant for permanent
injuries in a reasonable amount to be determined at the trial of this cause, for medical expenses,
lost wages, property damage including, but not limited to, diminished value, and other special
expenses, for future medical expenses, lost wages and other special expenses, court costs, and all
other proper relief in the premises.
-2-
SECOND CAUSE OF ACTION
Comes now the plaintiffs, Donna Hill, Kandace Marberry, and Kevin Washington, by
counsel, Ken Nunn Law Office, and for cause of action against the defendant, State Farm
Mutual Automobile Company, allege and say:
1. That they incorporate by reference all paragraphs of the First Cause of Action as
set out above.
2. That at the time of the collision, plaintiffs were insured by defendant under an
uninsured/underinsured Motorist Coverage Endorsement, Policy No. 3031074-B08-14C. See
copy of Certificate of Coverage attached hereto as Exhibit A.
3. That plaintiffs are making a claim for uninsured/underinsurance coverage in order
to be fully compensated for their injuries and damages suffered in said automobile accident,
which injuries and damages may exceed the amount of defendant’s policy limits.
4. That plaintiff has been injured and damaged in an amount to be proved at the trial
of this cause.
WHEREFORE, the plaintiffs demand judgment against the defendant for permanent
injuries in a reasonable amount to be determined at the trial of this cause, for medical expenses,
lost wages, property damage including, but not limited to, diminished value, and other special
expenses, for future medical expenses, lost wages, and other special expenses, court costs, and
all other proper relief in the premises.
KEN NUNN LAW OFFICE
BY: s/ Troy K. Rivera
Troy K. Rivera, #21803-49
KEN NUNN LAW OFFICE
104 South Franklin Road
Bloomington, IN 47404
Phone: (812) 332-9451
Fax: (812) 331-5321
E-mail: troyr@kennunn.com
-3-
REQUEST FOR TRIAL BY JURY
Comes now the plaintiffs, by counsel, Ken Nunn Law Office, and requests that this matter
be tried by jury pursuant to Trial Rule 38.
KEN NUNN LAW OFFICE
BY: s/ Troy K. Rivera
Troy K. Rivera, #21803-49
KEN NUNN LAW OFFICE
104 South Franklin Road
Bloomington, IN 47404
Phone: (812) 332-9451
Fax: (812) 331-5321
E-mail: troyr@kennunn.com
Troy K. Rivera, #21803-49
Ken Nunn Law Office
104 South Franklin Road
Bloomington, IN 47404
Telephone: 812-332-9451
Fax Number: 812-331-5321
Attorney for Plaintiff
Preview
45D01-2406-CT-000771 Filed: 6/18/2024 1:28 PM Clerk Lake Superior Court, Civil Division 1 Lake County, Indiana STATE OF INDIANA ) IN THE LAKE COURT ) SS: COUNTY OF LAKE ) CAUSE NO. DONNA HILL, KANDACE MARBERRY, and KEVIN WASHINGTON VS. LATISHA THOMAS-STREETER and STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY COMPLAINT FOR DAMAGES FIRST CAUSE OF ACTION Comes now the plaintiffs, Donna Hill, Kandace Marberry, and Kevin Washington, by counsel, Ken Nunn Law Office, and for cause of action against the defendant, Latisha Thomas- Streeter, alleges and says: 1. That on or about April 14, 2024, the defendant, Latisha Thomas-Streeter, negligently drove her vehicle, causing her vehicle to strike the vehicle driven by the plaintiff, Donna Hill, and in which plaintiffs, Kandace Marberry and Kevin Washington, were passengers. 2. That said collision occurred within the boundaries of Lake County, State of Indiana. 3. That the plaintiffs received permanent injuries, pain, suffering, and anguish as a result of the defendant's negligence. 4. That the plaintiffs have incurred medical expenses, lost wages, property damage including, but not limited to, diminished value, and other special expenses in an amount to be proven at the trial of this cause, and will incur future medical expenses, lost wages and other special expenses, as a direct and proximate result of defendant's negligence. WHEREFORE, the plaintiffs demand judgment against the defendant for permanent injuries in a reasonable amount to be determined at the trial of this cause, for medical expenses, lost wages, property damage including, but not limited to, diminished value, and other special expenses, for future medical expenses, lost wages and other special expenses, court costs, and all other proper relief in the premises. -2- SECOND CAUSE OF ACTION Comes now the plaintiffs, Donna Hill, Kandace Marberry, and Kevin Washington, by counsel, Ken Nunn Law Office, and for cause of action against the defendant, State Farm Mutual Automobile Company, allege and say: 1. That they incorporate by reference all paragraphs of the First Cause of Action as set out above. 2. That at the time of the collision, plaintiffs were insured by defendant under an uninsured/underinsured Motorist Coverage Endorsement, Policy No. 3031074-B08-14C. See copy of Certificate of Coverage attached hereto as Exhibit A. 3. That plaintiffs are making a claim for uninsured/underinsurance coverage in order to be fully compensated for their injuries and damages suffered in said automobile accident, which injuries and damages may exceed the amount of defendant’s policy limits. 4. That plaintiff has been injured and damaged in an amount to be proved at the trial of this cause. WHEREFORE, the plaintiffs demand judgment against the defendant for permanent injuries in a reasonable amount to be determined at the trial of this cause, for medical expenses, lost wages, property damage including, but not limited to, diminished value, and other special expenses, for future medical expenses, lost wages, and other special expenses, court costs, and all other proper relief in the premises. KEN NUNN LAW OFFICE BY: s/ Troy K. Rivera Troy K. Rivera, #21803-49 KEN NUNN LAW OFFICE 104 South Franklin Road Bloomington, IN 47404 Phone: (812) 332-9451 Fax: (812) 331-5321 E-mail: troyr@kennunn.com -3- REQUEST FOR TRIAL BY JURY Comes now the plaintiffs, by counsel, Ken Nunn Law Office, and requests that this matter be tried by jury pursuant to Trial Rule 38. KEN NUNN LAW OFFICE BY: s/ Troy K. Rivera Troy K. Rivera, #21803-49 KEN NUNN LAW OFFICE 104 South Franklin Road Bloomington, IN 47404 Phone: (812) 332-9451 Fax: (812) 331-5321 E-mail: troyr@kennunn.com Troy K. Rivera, #21803-49 Ken Nunn Law Office 104 South Franklin Road Bloomington, IN 47404 Telephone: 812-332-9451 Fax Number: 812-331-5321 Attorney for Plaintiff