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DocuSign Envelope ID: A2D079E0-DD5B-4990-BBEC-6F529649A524
20 124
COMMONWEALTH OF MASSACHUSETTS
HAMPSHIRE, ss SUPERIOR COURT DEPARTMENT
CIVIL ACTION NO:
AAMPSHIRF SUPERIOR COUR!
NOV 63 2020
REGINA POST,
Plaintiff
iARR: veKANUWOK) JR
COMPLAINT ANB 'SORY DERAND
HFS of AMERICA, INC. and
ERIC M. MOBERG,
Defendants
PARTIES
The Plaintiff, Regina Post is an individual residing at 607 Windcliff Circle,
Youngstown, OH at the time of this motor vehicle accident and currently residing
at 53 Stephens Street, Chicopee, MA
The Defendant, HFS of America, Inc. (“HFS”) is, on information and belief, a
Florida Corporation, which has a principal place of business at 413 River Rd.,
Hudson, Massachusetts.
The Defendant, Eric M. Moberg (“Moberg”), is an individual residing at 139
Union Road, Wales, MA at the time of this motor vehicle accident.
COUNTI
Negligenc
(Regina Post v. HFS of America, Inc.)
The Plaintiff repeats and realleges the preceding paragraphs of this Complaint and
incorporates same herein.
At all relevant times including on November 6, 2017, Plaintiff, Regina Post was a
passenger in an automobile, which was traveling on North Main Street, a public
way, in Belchertown, Massachusetts.
Atall relevant times including November 6, 2017, Defendant, HFS of America,
Inc. was the owner of the motor vehicle being operated by Defendant, Eric M.
DocuSign Envelope ID: A2D079E0-DD5B-4990-BBEC-6F529649A524
Moberg in a parking lot and on North Main St. in Belchertown, Massachusetts.
The Defendant, HFS of America, Inc.’s vehicle was being operated in an unsafe
manner when it slammed into the side of the vehicle in which Plaintiff was a
passenger.
The Defendants, HFS of America, Inc. and Eric M. Moberg owed a duty of care
to the Plaintiff Regina Post to ensure that the vehicle owned by HFS of America,
Inc. was being operated in a safe and careful manner.
Defendant, HFS of America, Inc. did breach said duty of care by allowing its
vehicle to be operated in a negligent and careless manner. Defendant, Eric M.
Moberg did breach said duty of care by operating said motor vehicle in a careless
and negligent manner.
Asa direct and proximate result of the negligence of the Defendant, HFS of
America, Inc., its employees, agents and for those whose actions it is responsible,
the Plaintiff, Regina Post has been caused to suffer, and continues to suffer severe
and permanent injuries including but not limited to right shoulder, low back, mid
back and neck pain requiring extensive medical care. The Plaintiff, Regina Post
has suffered great pain of body and mind and has been caused to incur substantial
medical expenses for her care, These losses are continuing in nature and Plaintiff
will continue to suffer from said losses in the future. She does not enjoy life as
she did prior to the occurrence.
WHEREFORE, the Plaintiff demands judginent and damages against the Defendant, HFS
of America, Inc., in a sum to be determined at trial, but sufficient to meet the
jurisdictional requirements of this Honorable Court, plus interest and costs
Negligence’
(Regina Post v. Eric M. Moberg)
10. The Plaintiff repeats and re-alleges the preceding paragraphs of this Complaint
and incorporates same herein.
11 Atall relevant times including on November 6, 2017, Plaintiff, Regina Post was
the passenger in an automobile, which was traveling on North Main Street, a
public way in Belchertown, Massachusetts.
12. At all relevant times including November 6, 2017, Defendant, HFS of America,
Inc. was the owner of the motor vehicle being operated by Defendant, Eric M.
Moberg in a parking Jot and then on North Main St, in Belchertown
Massachusetts. The Defendant, HFS of America Inc.’s vehicle was being operated
by Defendant, Eric M. Moberg in an unsafe manner when it slammed into the side
of the vehicle in which the Plaintiff was a passenger.
DocuSign Envelope ID: A2D079E0-DD5B-4990-BBEC-6F529649A524
13 The Defendants, HFS of America, Inc. and Eric M. Moberg owed a duty of care
to the Plaintiff, Regina Post to ensure that the vehicle owned by Defendant, HFS
of America, Inc. was being operated in a safe and careful manner.
14. Defendant, HFS of America, Inc. did breach said duty of care by allowing its
vehicle to be operated in a negligent and careless manner. Defendant, Eric M.
Moberg did breach said duty of care by operating said vehicle in an unsafe and
negligent manner.
15 As a direct and proximate result of the negligence of the Defendants, Eric M.
Moberg and HFS of America, Inc., its employees, agents and for those whose
actions it is responsible for, the Plaintiff, Regina Post has been caused to suffer,
and continues to suffer severe and permanent injuries, including but not limited to
right shoulder, low back, mid back and neck pain. The Plaintiff, Regina Post has
suffered great pain of body and mind and has been caused to incur substantial
medical expenses for her care. These Josses are continuing in nature and Plaintiff
will continue to suffer from said losses in the future. She does not enjoy life as he
did prior to the occurrence.
WHEREFORE, the Plaintiff demands judgment and damages against the
Defendant, Eric M. Moberg, in a sum to be determined at trial, plus interest and costs.
JURY DEMAND
PLAINTIFF, REGINA POST, DEMANDS A JURY TRIAL ON ALL ISSUES SO
TRIABLE.
11/3/2020
Dated :
RESPECTFULLY SUBMITTED
THE PLAINTIFF,
FER. TTORNEY
29FSCEOAZ36R524,
Thomas A. Kokonowski, Esq.
46 Main Street
Northampton, MA 01060
(413) 585-9200 phone
(413) 585-9201 fax
BBO# 564549
Email: adamskokonowski@gmail.com
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DocuSign Envelope ID: A2D079E0-DD5B-4990-BBEC-6F529649A524 20 124 COMMONWEALTH OF MASSACHUSETTS HAMPSHIRE, ss SUPERIOR COURT DEPARTMENT CIVIL ACTION NO: AAMPSHIRF SUPERIOR COUR! NOV 63 2020 REGINA POST, Plaintiff iARR: veKANUWOK) JR COMPLAINT ANB 'SORY DERAND HFS of AMERICA, INC. and ERIC M. MOBERG, Defendants PARTIES The Plaintiff, Regina Post is an individual residing at 607 Windcliff Circle, Youngstown, OH at the time of this motor vehicle accident and currently residing at 53 Stephens Street, Chicopee, MA The Defendant, HFS of America, Inc. (“HFS”) is, on information and belief, a Florida Corporation, which has a principal place of business at 413 River Rd., Hudson, Massachusetts. The Defendant, Eric M. Moberg (“Moberg”), is an individual residing at 139 Union Road, Wales, MA at the time of this motor vehicle accident. COUNTI Negligenc (Regina Post v. HFS of America, Inc.) The Plaintiff repeats and realleges the preceding paragraphs of this Complaint and incorporates same herein. At all relevant times including on November 6, 2017, Plaintiff, Regina Post was a passenger in an automobile, which was traveling on North Main Street, a public way, in Belchertown, Massachusetts. Atall relevant times including November 6, 2017, Defendant, HFS of America, Inc. was the owner of the motor vehicle being operated by Defendant, Eric M. DocuSign Envelope ID: A2D079E0-DD5B-4990-BBEC-6F529649A524 Moberg in a parking lot and on North Main St. in Belchertown, Massachusetts. The Defendant, HFS of America, Inc.’s vehicle was being operated in an unsafe manner when it slammed into the side of the vehicle in which Plaintiff was a passenger. The Defendants, HFS of America, Inc. and Eric M. Moberg owed a duty of care to the Plaintiff Regina Post to ensure that the vehicle owned by HFS of America, Inc. was being operated in a safe and careful manner. Defendant, HFS of America, Inc. did breach said duty of care by allowing its vehicle to be operated in a negligent and careless manner. Defendant, Eric M. Moberg did breach said duty of care by operating said motor vehicle in a careless and negligent manner. Asa direct and proximate result of the negligence of the Defendant, HFS of America, Inc., its employees, agents and for those whose actions it is responsible, the Plaintiff, Regina Post has been caused to suffer, and continues to suffer severe and permanent injuries including but not limited to right shoulder, low back, mid back and neck pain requiring extensive medical care. The Plaintiff, Regina Post has suffered great pain of body and mind and has been caused to incur substantial medical expenses for her care, These losses are continuing in nature and Plaintiff will continue to suffer from said losses in the future. She does not enjoy life as she did prior to the occurrence. WHEREFORE, the Plaintiff demands judginent and damages against the Defendant, HFS of America, Inc., in a sum to be determined at trial, but sufficient to meet the jurisdictional requirements of this Honorable Court, plus interest and costs Negligence’ (Regina Post v. Eric M. Moberg) 10. The Plaintiff repeats and re-alleges the preceding paragraphs of this Complaint and incorporates same herein. 11 Atall relevant times including on November 6, 2017, Plaintiff, Regina Post was the passenger in an automobile, which was traveling on North Main Street, a public way in Belchertown, Massachusetts. 12. At all relevant times including November 6, 2017, Defendant, HFS of America, Inc. was the owner of the motor vehicle being operated by Defendant, Eric M. Moberg in a parking Jot and then on North Main St, in Belchertown Massachusetts. The Defendant, HFS of America Inc.’s vehicle was being operated by Defendant, Eric M. Moberg in an unsafe manner when it slammed into the side of the vehicle in which the Plaintiff was a passenger. DocuSign Envelope ID: A2D079E0-DD5B-4990-BBEC-6F529649A524 13 The Defendants, HFS of America, Inc. and Eric M. Moberg owed a duty of care to the Plaintiff, Regina Post to ensure that the vehicle owned by Defendant, HFS of America, Inc. was being operated in a safe and careful manner. 14. Defendant, HFS of America, Inc. did breach said duty of care by allowing its vehicle to be operated in a negligent and careless manner. Defendant, Eric M. Moberg did breach said duty of care by operating said vehicle in an unsafe and negligent manner. 15 As a direct and proximate result of the negligence of the Defendants, Eric M. Moberg and HFS of America, Inc., its employees, agents and for those whose actions it is responsible for, the Plaintiff, Regina Post has been caused to suffer, and continues to suffer severe and permanent injuries, including but not limited to right shoulder, low back, mid back and neck pain. The Plaintiff, Regina Post has suffered great pain of body and mind and has been caused to incur substantial medical expenses for her care. These Josses are continuing in nature and Plaintiff will continue to suffer from said losses in the future. She does not enjoy life as he did prior to the occurrence. WHEREFORE, the Plaintiff demands judgment and damages against the Defendant, Eric M. Moberg, in a sum to be determined at trial, plus interest and costs. JURY DEMAND PLAINTIFF, REGINA POST, DEMANDS A JURY TRIAL ON ALL ISSUES SO TRIABLE. 11/3/2020 Dated : RESPECTFULLY SUBMITTED THE PLAINTIFF, FER. TTORNEY 29FSCEOAZ36R524, Thomas A. Kokonowski, Esq. 46 Main Street Northampton, MA 01060 (413) 585-9200 phone (413) 585-9201 fax BBO# 564549 Email: adamskokonowski@gmail.com