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UL
COMMONWEALTH OF MASSACHUSETTS
Middlesex, SS. SUPERIOR COURT DEPARTMENT
CIVIL ACTION NO.: J 7- SI
)
JUSTIN URBAN )
Plaintiff d
VS. COMPLAINT
ee
KEITH WESTON and fo FILED ;
INTERSTATE ELECTRICAL SERVICES CORP. ) gu URIS
Defendant’s ; | FORTHE COUNT: esex |
) ~ MAR 16 2017,
0 Cbs
Now comes the Plaintiff in the above-entitled action and say as follows:
THE PARTIES
a. That the Plaintiff, Justin Urban is a resident of 16 Dartmouth Drive,
Billerica, Middlesex County, Massachusetts.
b. That the Defendant, Keith Weston, is a resident of and/or has an usual place
of business at 12 Westgate Road, North Billerica, Middlesex County,
Massachusetts.
c. That the Defendant, Interstate Electrical Services Corp. is a resident of
and/or has an usual place of business at 70 Treble Cove Road, Billerica,
Middlesex County, Massachusetts.
COUNT 1:
1. The Plaintiff, Justin Urban says that on or about September 12, 2014, he was
lawfully operating a motorcycle upon Boston Road, which is a public way in
Billerica, Massachusetts.
2. That he was operating through a green traffic signal and had the right of
way pursuant to G.L. Chapter 89 §8.
3. That the Defendant, Keith Weston, then and there so negligently and
carelessly operated a motor vehicle as to cause said motor vehicle to strike the
motorcycle operated by the Plaintiff.
4. That as a consequence thereof, the Plaintiff was caused to sustain serious
personal injuries.
5, That as a consequence of sustaining serious personal injuries, as aforesaid,
the Plaintiff sustained a fracture and/or serious and permanent disfigurementand/or incurred in excess of Two Thousand Dollars ($2,000.00) in medical
expenses.
6. That as a consequence of sustaining serious personal injuries as aforesaid,
the Plaintiff suffered and continues to suffer great pain, both of body and mind,
suffered and continues to suffer diminution of earning capacity, and incurred
and continues to incur great expense for medicines and medical attention.
7. Wherefore, the Plaintiff, Justin Urban, claims damages and demands
judgement against the Defendant, Keith Weston, with interest and costs.
JURY CLAIM
The Plaintiff, Justin Urban, claims a jury trial in the Superior Court on this
cause of action.
COUNT 2:
1. The Plaintiff, Justin Urban says that on or about September 12, 2014, he was
lawfully operating a motorcycle upon Boston Road, which is a public way in
Billerica, Massachusetts.
2. That an agent, servant, or employee of the Defendant, Interstate Electrical
Services Corp., then and there so negligently and carelessly operated a motor
vehicle as to cause said motor vehicle to strike the motor vehicle operated by
the Plaintiff.
3. That as a consequence thereof, the Plaintiff was caused to sustain serious
personal injuries.
4. That as a consequence of sustaining serious personal injuries, as aforesaid,
the Plaintiff sustained a fracture and/or serious and permanent disfigurement
and/or incurred in excess of Two Thousand Dollars ($2,000.00) in medical
expenses.
5. That as a consequence of sustaining serious personal injuries as aforesaid,
the Plaintiff suffered and continues to suffer great pain, both of body and mind,
suffered and continues to suffer diminution of earning capacity, and incurred
and continues to incur great expense for medicines and medical attention.
6. Wherefore, the Plaintiff, Justin Urban, claims damages and demands
judgment against the Defendant, Interstate Electrical Services Corp., with
interest and costs.
JURY CLAIM
The Plaintiff, Justin Urban, claims a jury trial in the Superior Court on this
cause of action.Dated: March 15, 2017
By His Attorney,
Richard S. McLaughlin
LAW OFFICE OF
RICHARD S. MCLAUGHLIN
6 Edgerly Place
Boston, MA 02116
Tel.: (617) 728-8630
BBO#: 550424a
a
CIVIL ACTION COVER SHEET DOCKET NUMBER Trial Court of Massachusetts
: . 4
/ 7- SIO ; The Superior Court
PLAINTIFF(S): Justin Urban COUNTY
. Middlesex
ADDRESS: 16 Dartmouth Drive
Billerica, MA 01821 DEFENDANT(S): Keith Weston
Interstate Elecrical Services Corp.
ATTORNEY: Richard S. McLaughlin
ADDRESS: 6 Edgerly Place ADDRESS: 12 Westgate Road, Billerica, MA 01821
Boston, MA 0216 70 Treble Cove Road, Billerica, MA 01821
BBO: 550424
TYPE OF ACTION AND TRACK DESIGNATION (see reverse side)
CODE NO. TYPE OF ACTION (specify) TRACK HAS A JURY CLAIM BEEN MADE?
B03 Motor Vehicle Negligence - Personal Injury F Jno
“If “Other” please describe:
STATEMENT OF DAMAGES PURSUANT TO G.L. c. 212, § 3A
The following is a full, temized and detailed statement of the facts on which the undersigned plaintiff or plaintiff counsel relies to determine money damages. For
this form, disregard double or treble damage claims; indicate single damages only.
ORT CLAIMS
(attach additional sheets as necessary)
A. Documented medical expenses to dat 312,607.36
1. Total hospital expenses .... —_
2. Total doctor expenses ...
3. Total chiropractic expenses
4. Total physical therapy expenses 3407.78
5. Total other expenses (describe below) .. 2,627.15
25,000.00
B. Documented lost wages and compensation to date
C. Documented property damages to dated ...
D. Reasonably anticipated future medical and hospital expenses ..
E, Reasonably anticipated lost wages ..
F. Other documented items of damage:
IG. Briefly describe plaintiff's injury, including the nature and extent of injury:
TOTAL (A-F):$ 358,642.29
CONTRACT CLAIMS
(attach additional sheets as necessary)
Provide a detailed description of claims(s):
TOTAL: $
Signature of Attorney/Pro Se Plaintiff: X Date: March 15, 2017
IRELATED ACTIONS: Please provide the case number, case name, and county of any related actions pending in the Superior Court.
CERTIFICATION PURSUANT TO SJC RULE 1:18
I hereby certify that | have complied with requirements of Rule 5 of the Supreme Judicial Court Uniform Rules on Dispute Resolution (SJC.
Rule 1:18) requiring that | provide my clients with informatign about court-connected dispute resolution services and discuss with them the
advantages and disadvantages of the various methods of dispute resolution.
~ ——— Date; March 15, 2017
i d: X
[Signature of Attorney of Recorc he
C7
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UL COMMONWEALTH OF MASSACHUSETTS Middlesex, SS. SUPERIOR COURT DEPARTMENT CIVIL ACTION NO.: J 7- SI ) JUSTIN URBAN ) Plaintiff d VS. COMPLAINT ee KEITH WESTON and fo FILED ; INTERSTATE ELECTRICAL SERVICES CORP. ) gu URIS Defendant’s ; | FORTHE COUNT: esex | ) ~ MAR 16 2017, 0 Cbs Now comes the Plaintiff in the above-entitled action and say as follows: THE PARTIES a. That the Plaintiff, Justin Urban is a resident of 16 Dartmouth Drive, Billerica, Middlesex County, Massachusetts. b. That the Defendant, Keith Weston, is a resident of and/or has an usual place of business at 12 Westgate Road, North Billerica, Middlesex County, Massachusetts. c. That the Defendant, Interstate Electrical Services Corp. is a resident of and/or has an usual place of business at 70 Treble Cove Road, Billerica, Middlesex County, Massachusetts. COUNT 1: 1. The Plaintiff, Justin Urban says that on or about September 12, 2014, he was lawfully operating a motorcycle upon Boston Road, which is a public way in Billerica, Massachusetts. 2. That he was operating through a green traffic signal and had the right of way pursuant to G.L. Chapter 89 §8. 3. That the Defendant, Keith Weston, then and there so negligently and carelessly operated a motor vehicle as to cause said motor vehicle to strike the motorcycle operated by the Plaintiff. 4. That as a consequence thereof, the Plaintiff was caused to sustain serious personal injuries. 5, That as a consequence of sustaining serious personal injuries, as aforesaid, the Plaintiff sustained a fracture and/or serious and permanent disfigurementand/or incurred in excess of Two Thousand Dollars ($2,000.00) in medical expenses. 6. That as a consequence of sustaining serious personal injuries as aforesaid, the Plaintiff suffered and continues to suffer great pain, both of body and mind, suffered and continues to suffer diminution of earning capacity, and incurred and continues to incur great expense for medicines and medical attention. 7. Wherefore, the Plaintiff, Justin Urban, claims damages and demands judgement against the Defendant, Keith Weston, with interest and costs. JURY CLAIM The Plaintiff, Justin Urban, claims a jury trial in the Superior Court on this cause of action. COUNT 2: 1. The Plaintiff, Justin Urban says that on or about September 12, 2014, he was lawfully operating a motorcycle upon Boston Road, which is a public way in Billerica, Massachusetts. 2. That an agent, servant, or employee of the Defendant, Interstate Electrical Services Corp., then and there so negligently and carelessly operated a motor vehicle as to cause said motor vehicle to strike the motor vehicle operated by the Plaintiff. 3. That as a consequence thereof, the Plaintiff was caused to sustain serious personal injuries. 4. That as a consequence of sustaining serious personal injuries, as aforesaid, the Plaintiff sustained a fracture and/or serious and permanent disfigurement and/or incurred in excess of Two Thousand Dollars ($2,000.00) in medical expenses. 5. That as a consequence of sustaining serious personal injuries as aforesaid, the Plaintiff suffered and continues to suffer great pain, both of body and mind, suffered and continues to suffer diminution of earning capacity, and incurred and continues to incur great expense for medicines and medical attention. 6. Wherefore, the Plaintiff, Justin Urban, claims damages and demands judgment against the Defendant, Interstate Electrical Services Corp., with interest and costs. JURY CLAIM The Plaintiff, Justin Urban, claims a jury trial in the Superior Court on this cause of action.Dated: March 15, 2017 By His Attorney, Richard S. McLaughlin LAW OFFICE OF RICHARD S. MCLAUGHLIN 6 Edgerly Place Boston, MA 02116 Tel.: (617) 728-8630 BBO#: 550424a a CIVIL ACTION COVER SHEET DOCKET NUMBER Trial Court of Massachusetts : . 4 / 7- SIO ; The Superior Court PLAINTIFF(S): Justin Urban COUNTY . Middlesex ADDRESS: 16 Dartmouth Drive Billerica, MA 01821 DEFENDANT(S): Keith Weston Interstate Elecrical Services Corp. ATTORNEY: Richard S. McLaughlin ADDRESS: 6 Edgerly Place ADDRESS: 12 Westgate Road, Billerica, MA 01821 Boston, MA 0216 70 Treble Cove Road, Billerica, MA 01821 BBO: 550424 TYPE OF ACTION AND TRACK DESIGNATION (see reverse side) CODE NO. TYPE OF ACTION (specify) TRACK HAS A JURY CLAIM BEEN MADE? B03 Motor Vehicle Negligence - Personal Injury F Jno “If “Other” please describe: STATEMENT OF DAMAGES PURSUANT TO G.L. c. 212, § 3A The following is a full, temized and detailed statement of the facts on which the undersigned plaintiff or plaintiff counsel relies to determine money damages. For this form, disregard double or treble damage claims; indicate single damages only. ORT CLAIMS (attach additional sheets as necessary) A. Documented medical expenses to dat 312,607.36 1. Total hospital expenses .... —_ 2. Total doctor expenses ... 3. Total chiropractic expenses 4. Total physical therapy expenses 3407.78 5. Total other expenses (describe below) .. 2,627.15 25,000.00 B. Documented lost wages and compensation to date C. Documented property damages to dated ... D. Reasonably anticipated future medical and hospital expenses .. E, Reasonably anticipated lost wages .. F. Other documented items of damage: IG. Briefly describe plaintiff's injury, including the nature and extent of injury: TOTAL (A-F):$ 358,642.29 CONTRACT CLAIMS (attach additional sheets as necessary) Provide a detailed description of claims(s): TOTAL: $ Signature of Attorney/Pro Se Plaintiff: X Date: March 15, 2017 IRELATED ACTIONS: Please provide the case number, case name, and county of any related actions pending in the Superior Court. CERTIFICATION PURSUANT TO SJC RULE 1:18 I hereby certify that | have complied with requirements of Rule 5 of the Supreme Judicial Court Uniform Rules on Dispute Resolution (SJC. Rule 1:18) requiring that | provide my clients with informatign about court-connected dispute resolution services and discuss with them the advantages and disadvantages of the various methods of dispute resolution. ~ ——— Date; March 15, 2017 i d: X [Signature of Attorney of Recorc he C7