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9-22-17 draft ______________ In the 8th Circuit Court of…

9-22-17 draft ______________ In the 8th...

9-22-17 draft
______________
In the 8th Circuit Court of Cheshire County
State of New HampshirePlaintiff, Amy Zuckerman
Vs,
Defendant, ***** *****COMPLAINTNow comes the Plaintiff, Amy Zuckerman, and files this complaint against the Defendant, ***** ***** and for cause would show unto the court as follows, to wit:
1) The Plaintiff, Amy Zuckerman, is an adult resident citizen of Hampshire County in whose residence is***** Amherst, Mass. 010022) The Defendant, ***** *****, is an adult resident citizen of Cheshire County in whose residence is*****, Marlborough, N.H., 03455, and listed his address on court documents as P.O. Box 285.3) At the times therein mentioned, the defendant was the operator of a jeep, which was the vehicle he was driving at the time of the accident that took place on October 30, 2016 that is the basis of the complaint thereof.4) On the date above mentioned, Plaintiff was driving her vehicle in a safe and prudent manner and was proceeding south on Rt. 10 in Winchester, N.H. just past the section of the road known as Manning Hill.5) Due to the careless and negligent actions by Plaintiff said vehicle was involved in a violent collision where the result thereof was that Plaintiff sustained severe and disabling injuries.6) At the time herein complained of, the vehicle operated by the Defendant side-swiped the Plaintiff’s car in a fashion that crushed the driver’s door and make it impossible to open.7) To exit the vehicle, the Defendant was forced to climb over the transmission stick and push open the passenger door, which was still functional.8) In the process, the Defendant wrenched her back in a way that seriously aggravated a torn disk.9) The collision also smashed the back door panel and front wheel,and did damage to the driver’s seat, the undercarriage of the car, including the struts, exhaust system, the driver side wheel, steering rod and passenger side wheel, which led to car repairs of almost $8,000 and the Plaintiff having to cease use of the vehicle on Sept. 13, 2017 as it became dangerous to drive.
10) The driver’s side tire went flat, which made it impossible to drive the car except to pull it off this dangerous stretch of road, and meant that the Winchester police later order the plaintiff to reach a tow truck as they deemed the car not operable.
11) The Defendant stopped his car, which was heading north, about an eighth of a mile up the road, and left his vehicle for a period of about 10 minutes, during which time the Plaintiff reached the Winchester police to report on the accident.
12) She saw lights flashing near his jeep from cars heading south, which stopped and swerved to miss the Defendant, who was lying prone on the northbound lane.
13) The Defendant, with the Winchester police on the phone, described all and then stopped a motorist heading north so she would not run over the Defendant.
14) The Defendant watched him get up, collect items on the ground, get into his vehicle and leave the scene of the accident.
15) The Defendant was able to gain evidence of the Plaintiff’s appearance and the make of his jeep from one of the cars that had stopped and swerved to miss him.
16) The police took this information and were able to apprehend the Defendant, who was later convicted of drunk driving with possession of an open bottle of alcohol in his car, though not charged with leaving the scene of the accident,
17) The defendant was released on $3,000 personal recognizance under the conditions he not possess a firearm, destructive device, dangerous weapon or ammunition, and he refrain from excessive use of alcohol, and use of a narcotic drug or controlled substance as defined in RSA 318-B.
18) The defendant pleaded guilty of this first offense and was referred to an impaired driver care management program, and had his driver’s license and privilege to drive revoked for nine months from the judgement on March 28, 2017.To summarize, the Defendant:

Lawyer's Assistant: License regulations vary from place to place, so can you tell me what state this is in?

I need a quick read on this personal injury complaint I drafted for a slam dunk NH case. Guy pleaded guilty. I was the DA's witness. The judge and his lawyer advised me to file the civil case, so likely this fits under civil, but I chose criminal to get it posted.

Lawyer's Assistant: Have you talked to a lawyer yet?

NH Yes, two NH lawyers reviewed my complaint and recommended edits. I made them. All I need is someone to review the complaint as drafted. I can go into court pro se.

Lawyer's Assistant: Anything else you want the lawyer to know before I connect you?

Can you read the complaint? If not, I will email it. New Hampshire court

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Answered in 2 minutes by:
10/2/2017
Ray
Ray, Lawyer
Category: Legal
Satisfied Customers: 46,254
Experience: 30 years in civil, probate, real estate, elder law
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Hi and welcome to JA. Ray here to help you today.Please bear with me a few moments while I review your question and respond.

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This appears fine with the edits you describe.I wish you the best here, sorry you had to go through this.It is a terrible thing.I wish you the best here.I have no more changes.

Thanks again and thanks for rating 5 stars.

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Customer reply replied 6 months ago
Thanks, Ray.Where are you located? I am what my defense attorney mentor calls a "legal agent" in Massachusetts. I drafted the complaint and had a look see from two seasoned NH defense attorneys. Both are very busy, so I decided to get another description. This guy is bad news.If you want any help I could use some work.(###) ###-####in western Mass.

Sorry I am not allowed clients off site under terms of service with JA.I do wish you the best here.Thanks

Ray
Ray, Lawyer
Category: Legal
Satisfied Customers: 46,254
Experience: 30 years in civil, probate, real estate, elder law
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