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

ROBERSON v. ADANALIC 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: 
3:15-cv-00720 Search Pacer
ACE Group party(s): 
Opposing Party: 
Willie Roberson
Court Type: 
Federal
US District Court: 
Middle District of Louisiana
Date Filed: 
Oct 28 2015

PETITION FOR DAMAGES

The petition of Willie Roberson, a major individual, domiciled in the Parish of
East Baton Rouge, State of Louisiana, respectfully represents:

Male defendants herein are:
SALIH ADANALIC, a major individual domiciled at 3227 Iiighgate Ave.
SW, Wyoming, MI 49509;
SD TRUCKING, INC., a foreign corporation not authorized to do but
doing business in the State of Louisiana with its principle place of business
located at 12337 East D Ave., Richland, MI 49083; and
ACE AMERICAN INSURANCE COMPANY, a foreign insurance
company authorized to do and doing business in the Parish of East Baton
Rouge, State of Louisiana.

Defendants, Salih Adanalic, SD Trucking, Inc., and Ace American Insurance
Company are justly and truly indebted, jn solido. unto petitioner in an amount that is just
and reasonable under the premises, for all elements of damage allowed by Louisiana law,
with legal interest thereon from date of judicial demand until paid, and for all costs of
these ngs, for the following, to wit:

On or about January 18, 2014 plaintiff Willie Roberson was operating a 2009
Chevrolet Impkla and traveling north on La. Highway 30 in the Parish of Iberville, State
of Louisiana and was stopped at the intersection of La. Highway 30 and Bayou Paul Lane
at the red light. Thereafter a 2005 eighteen wheel tractor trailer, owned by SD Trucking,
Inc. and operated by Salih Adanalic, which was also traveling north on La. Highway 30,
entered the intersection of La. Highway 30 and Bayou Paul Lane and stopped, reversed
his vehicle! and backed into plaintiffs automobile.
4.
Due to the above-described accident, plaintiff sustained painful injuries, including
but not limited to injuries to his lumbar spine, left leg and knee.
5.
above-described accident and plaintiffs resulting injuries were proximately
caused by tie fault and negligent acts and omissions of Salih Adanalic, in the following
ve particulars:
Breach of a legally imposed duty of reasonable care;
At the time of the above-described accident, defendant Ace American Insurance
Company had in full force and effect, a policy of automobile liability insurance, policy
number CT788268-5012-122 providing coverage to defendant, Salih Adanalic, as
operator of the aforesaid vehicle and therefore, Ace American Insurance Company is
liable, in so ido. with its insured for all amounts due to plaintiff pursuant to Louisiana
Revised Statute 22:1269.

Plain :iff Willie Roberson claims such damages that are just and reasonable under
the premises, for damages, past, present, and future, for mental anguish, emotional
distress, pain and suffering, medical bills, loss of enjoyment of life, lost wages, loss of
wage earning capacity, physical disability and all other elements of damages allowed by
Louisiana law.

Plaint ff respectfully requests written notice to his counsel ten days in advance of
the date fixed for trial or hearing on any exception, motion, rule or trial on the merits in
this proceeding pursuant to Louisiana Code of Civil Procedure Article 1572, and plaintiff
further requests pursuant to Louisiana Code of Civil Procedure Articles 1913 and 1914
immediate notice to his counsel of all interlocutory and final orders and judgments on any
exceptions otions, rules or trial on the merits in these proceedings.

Failure to see what he should have seen and observe the vehicle located
behind him;
Failing to take proper evasive action;
Negligently entering the intersection against the traffic control sign;
Operating his vehicle in a careless and inattentive manner;
Violation of statutes enacted in Title 32 of the Louisiana Revised
Statutes;
Negligently backing his vehicle into plaintiffs vehicle; and
Other negligent acts and omissions to be proved at the trial of this cause.
times pertinent hereto, specifically on or about January718, 2014, Salih
employed by and acting within the course and scope of his duties with SD
., which, by the virtue of the doctrine of respondent superior and Louisiana
Article 2320, is liable, in solido. with its employee, Salih Adanalic, and for his
negligent actis and/or omissions and for all amounts owed to plaintiff.

WHEREFORE, plaintiff Willie Roberson prays that defendants Salih Adanalic,
SD Trucking Inc., and Ace American Insurance Company be duly cited and served with
this Petition for Damages, be required to appear and answer same and, after the expiration
of all legal delays and due proceedings had, that there be judgment rendered herein in
favor of petitioner, and against defendants, for all such damages as are reasonable in the
premises, with legal interest thereon from date of judicial demand until paid, for all costs
of these proceedings, and for all other general and equitable relief.

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.

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