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ROBERSON v. ADANALIC et al complaint

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WILLIE ()BERSON
VERSU
SALIH ApANALIC, SD TRUCKING,
INC., AN ACE AMERICAN
INSURA CE COMPANY
* * * *  * * * * * * * * * * * * * * * * *
1 0 1
• NUMBERIW\ \ DIVISION:
• 1 8' JUDICIAL DISTRICT COURT
• PARISH OF IBERVILLE
• STATE OF LOUISIANA
* * * * * * * * * * * * * * * * * * * * * * * * * * * * *
PETITION FOR DAMAGES
Th petition of Willie Roberson, a major individual, domiciled in the Parish of
East Bato Rouge, State of Louisiana, respectfully represents:
1 .
Ma e defendants herein are:
1 )  SALIH ADANALIC, a major individual domiciled at 3227 Highgate Ave.
SW, Wyoming, MI 4950 9;
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 1 2337 East D Ave., Richland, MI 490 83; 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.
2.
Defe ants, Salih Adanalic, SD Trucking, Inc., and Ace American Insurance
Company ar justly and truly indebted, in solid°, unto petitioner in an amount that is just
and reasonab e under the premises, for all elements of damage allowed by Louisiana law,
with legal int rest thereon from date of judicial demand until paid, and for all costs of
these proceed ngs, for the following, to wit:
3.
On or out January 1 8, 20 1 4 plaintiff Willie Roberson was operating a 20 0 9
Chevrolet Imp la and traveling north on La. Highway 30 in the Parish of Iberville, State
of Louisiana a d was stopped at the intersection of La. Highway 30 and Bayou Paul Lane
at the red light. Thereafter a 20 0 5 eighteen wheel tractor trailer, owned by SD Trucking,
Case 3:15-cv-00720-SDD-SCR Document 1-1 10/28/15 Page 1 of 17
A
Inc. and o crated by Salih Adanalic, which was also traveling north on La. Highway 30 ,
entered th intersection of La. Highway 30 and Bayou Paul Lane and stopped, reversed
his vehicl and backed into plaintiffs automobile.
4.
Du1 to the above-described accident, plaintiff sustained painful injuries, including
but not li ted to injuries to his lumbar spine, left leg and knee.
5.
The above-described accident and plaintiffs resulting injuries were proximately
caused by t e fault and negligent acts and omissions of Salih Adanalic, in the following
non-exclus ye particulars:
1 ) Breach of a legally imposed duty of reasonable care;
2) Failure to see what he should have seen and observe the vehicle located
behind him;
3) Failing to take proper evasive action;
4) Negligently entering the intersection against the traffic control sign;
5) Operating his vehicle in a careless and inattentive manner;
6) Violation of statutes enacted in Title 32 of the Louisiana Revised
Statutes;
7) Negligently backing his vehicle into plaintiffs vehicle; and
8) Other negligent acts and omissions to be proved at the trial of this cause.
6.
At al times pertinent hereto, specifically on or about January 1 8, 20 1 4, Salih
Adanalic w employed by and acting within the course and scope of his duties with SD
Trucking, In which, by the virtue of the doctrine of respondent superior and Louisiana
Civil Code
A
rticle 2320 , is liable, in solid°, with its employee, Salih Adanalic, and for his
negligent ac u and/or omissions and for all amounts owed to plaintiff.
2
Case 3:15-cv-00720-SDD-SCR Document 1-1 10/28/15 Page 2 of 17
7.
At the time of the above-described accident, defendant Ace American Insurance
1
Company 1 ad in full force and effect, a policy of automobile liability insurance, policy
number CT788268-50 1 2-1 22 providing coverage to defendant, Salih Adanalic, as
operator of the aforesaid vehicle and therefore, Ace American Insurance Company is
liable, in solid°, with its insured for all amounts due to plaintiff pursuant to Louisiana
Revised Sta te 22:1 269.
8.
Plain iff Willie Roberson claims such damages that are just and reasonable under
the premise , for damages, past, present, and future, for mental anguish, emotional
distress, paii and suffering, medical bills, loss of enjoyment of life, lost wages, loss of
wage earnin capacity, physical disability and all other elements of damages allowed by
Louisiana la
9.
Plaint ff respectfully requests written notice to his counsel ten days in advance of
the date fixei for trial or hearing on any exception, motion, rule or trial on the merits in
this proceedi g pursuant to Louisiana Code of Civil Procedure Article 1 572, and plaintiff
further reque ts pursuant to Louisiana Code of Civil Procedure Articles 1 91 3 and 1 91 4
immediate n ice to his counsel of all interlocutory and final orders and judgments on any
exceptions, otions, rules or trial on the merits in these proceedings.
WHE', FORE, plaintiff Willie Roberson prays that defendants Salih Adanalic,
SD Trucking, Inc., and Ace American Insurance Company be duly cited and served with
this Petition f r Damages, be required to appear and answer same and, after the expiration
of all legal de ays 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 proce dings, and for all other general and equitable relief.
3
Case 3:15-cv-00720-SDD-SCR Document 1-1 10/28/15 Page 3 of 17
20 1 5 JAN 1 2 P
1 2: 5
/s/Kriste n B. Crowson
-EX OFFICIAL
E. LOUISIANA
DY CLER
IBERVIL
4
Respectfully. submitted:
BOHRER LAW FIRM, L.L.C.
871 2 Jefferson Highway, Suite B
Baton Rouge, LA 70 80 9
Tel: (225)925-5297
Phili Bo rer
Bar'oil o: 1 40 89
By:
SERVIC INFORMATION:
Please se e:
Salih Ad alic (via long arm statute)
3227 Hig gate Ave SW
Wyoming, MI 4950 9
-an
SD Trucki 1 g, Inc. (via long arm statute)
Through it agent for service of process:
Sean Devr u
1 2337 East D Ave.
Richland, d490 83
-and
Ace Americ Insurance Company
Through its gent for service of process:
Louisiana S;cretary of State
3851 Essen I ane
Baton Roug LA 70 80 9
FLED
Case 3:15-cv-00720-SDD-SCR Document 1-1 10/28/15 Page 4 of 17

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date: 
Wed, 2015-10-28
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