Skip to Navigation
The Collaborative Clearinghouse for Lawsuits and Other Claims Against ACE Group Insurance Companies

LAVERGNE v. HATCHER et al

ATTENTION: It is possible that this information may no longer be current and therefore may be inaccurate. The index contains both open and closed cases and is not a complete list of cases in which an ACE Insurance Group company is involved. This information is provided to give interested persons an idea of the issues disputed in the indexed cases. For a full understanding of a case, one should read the rest of the court file, including the response. For the most up-to-date and complete information on a case, visit www.pacer.gov or contact the clerk of the relevant court.

Case Number: 
6:11-cv-00898 Search Pacer
ACE Group party(s): 
Opposing Party: 
Arline C Lavergne
Court Type: 
Federal
US District Court: 
Western District of Louisiana
Date Filed: 
Jun 16 2011

"Transportation, LLC (hereinafter referred to as “Employer”) on the roadway, when Tortfeasor’s vehicle struck the vehicle driven and occupied by Plaintiff causing Plaintiffs’ injuries and damages.

VIII. Plaintiff was totally free from any fault whatsoever in causing or contributing to the crash.

IX. Upon information and belief and at all times relevant herein, the aforementioned accident and/or collision were caused totally, solely and/or concurrently through the negligence and/or fault of the Defendants in the following non-exclusive particulars, to-wit:

a. Operating a motor vehicle in an unsafe manner;
b. Inattentiveness;
c. Failure to maintain a proper lookout;
d. Careless operation of a motor vehicle;
e. Failure to discharge any and all duties owed to a person in the capacity of Plaintiffs; and
f. Violations of laws, statutes and/or regulations designed for the safety of the motoring public
and/or their motor vehicles.
X. Plaintiff itemizes past, present and future damages to include but not be limited to the following:
a. Medical Expenses;
b. Loss of earnings and impaired earning capacity;
c. Physical pain and suffering;
d. Humiliation;
e. Shame;
f. Embarrassment;
g. Isolation;
h. Despair;
i. Loss of Mobility;
j. Mental distress, worry and anxiety;
k. Emotional trauma and insecurity;
l. Permanent disability and inconvenience;
m. Scarring and disfigurement;
n. Loss of enjoyment of life;
o. Punitive and Exemplary Damages;
p. Attorney’s Fees;
q. Legal interest from the date of judicial demand; and
r. All costs of court and expenses incurred in the prosecution of this litigation.

XI. At all times mentioned herein, National Union Fire Insurance Company of Pittsburgh, PA issued a policy of insurance to Vision Logistics Holding Corporation that was in full force and effect and extended coverage to the vehicle, driven with permission by Owner and provided insurance coverage for the collision forming the subject matter of this litigation that occurred on the date of the subject incident, and to the injuries and damages sustained by the Plaintiffs herein.

XII. At all times mentioned herein, Zurich American Insurance Company issued a policy of insurance to Vision Logistics Holding Corporation, that was in full force and effect and extended coverage to the vehicle, driven with permission by Owner and provided insurance coverage for the collision forming the subject matter of this litigation that occurred on the date of the subject incident, and to the injuries and damages sustained by the Plaintiff herein.

XIII. At all times mentioned herein, Alfa Insurance Corporation issued a policy of insurance to Stanley Jay Hatcher that was in full force and effect and extended coverage to the vehicle, driven with permission by Owner and provided insurance coverage for the collision forming the subject matter of this litigation that occurred on the date of the subject incident, and to the injuries and damages sustained by the Plaintiff herein.

XIV. At all times mentioned herein, Ace American Insurance Company issued a policy of insurance to Employer that was in full force and effect and extended coverage to the vehicle, driven with permission by Owner and provided insurance coverage for the collision forming the subject matter of this litigation that occurred on the date of the subject incident, and to the injuries and damages sustained by the Plaintiff herein.

XV. Upon information and belief and at all times relevant herein, Zurich American Insurance Company issued one or more policies of uninsured motorist insurance coverage to Plaintiff that were in effect and provided insurance coverage to Employer that was in full force and effect on the vehicle owned by Larry Patin and operated by Plaintiff for the injuries and damages suffered by Plaintiffs.

XVI. Plaintiffs are entitled to and hereby request that Defendants produce for inspection, the original or a certified copy of all insurance policies which were issued and arguably provide coverage for accident and damages complained of herein, said policy(ies) to be produced within thirty (30) days to D. Patrick Daniel, Jr., LLC, Counsel For Plaintiffs.

XVII. Plaintiff prays that:

a. Defendants be duly summoned and served with a copy of this Complaint For Damages;
b. After all legal delays and due proceedings be had, there be judgment rendered herein in favor of Plaintiff and against Defendants, jointly, severally and in solido, in the full and true sum of an amount reasonable in the premises, maintenance, cure, punitive damages, attorneys’ fees, plus legal interest thereon from the date of incident until paid, all costs of these proceedings and all other equitable and just relief;
c. Plaintiff be given Notice of Judgment, Trial and all steps and action taken in this litigation under Federal Rules of Civil Procedure."

The provided text is an excerpt from a document filed in this case. For a full understanding of the case, one should read the complete court file, including the response.

Javascript is required to view this map.