Reference no: EM133286242

Assignment:

Write a properly formatted Answer to the Complaint shown below Make sure to include any Affirmative Defenses, Counterclaims, or Cross Claims that the Defendant in the litigation might raise.

Complaint:

Plaintiff Paula Harris brings forth the following causes of action and alleges the

Following:

1. Plaintiff is a resident of Virginia
2. The defendant is a resident of Maryland
3. This is a civil action for personal injuries sustained by Paula Harris due to the negligence of Officer Drew Preston of the Anne Arundel County, Maryland Police Department.
4. On February 17, 2018, at approximately 10 p.m., the defendant was on duty conducting police patrols in his assigned marked patrol car. He was dispatched to a burglary in progress.
5. The defendant activated his patrol car emergency lights and siren and proceeded through the intersection of Crain Highway and Hospital Drive without stopping for the red light.
6. As the defendant drove through the intersection, he collided with Harris' vehicle.
7. The Plaintiff suffered several physical injuries in the accident, including a broken right arm, two fractured ribs, and pain in her neck. Plaintiff was hospitalized for two days, and her medical bills totaled $178,000.

COUNT 1 - NEGLIGENCE.

The defendant was negligent in failing to stop at the red light, and his negligence was the cause of the plaintiff's injuries.

The defendant's negligence was the cause of Ms. Harris' injuries and resulting damages. The plaintiff suffered economic and non-economic damages due to the accident.

DAMAGES

Wherefore, the plaintiff is seeking compensatory damages in the amount of not less than $178,000, together with punitive damages, costs of suit and any other relief the court deems just and proper.