Litigation Complaint , law homework help

COMPLAINTASSIGNMENTReadthe attached fact situation.  Ms. StellaKing  comes to your law firm, Jones &Jones, P.C., to request that your firm file a lawsuit against Donald Woods.  Your supervising attorney asks you to draft acomplaint in the matter of King v. Woods based on automobile negligence.  Ms. King lives in Bloomfield Hills, MI.  Donald Woods is a resident of Plymouth Township,Michigan.  You are to ask for a jurytrial.Pleaserely primarily on the facts as they appear in the Factual Statement.  You may make up such things as names ofattorneys, addresses, etc.  Yourcomplaint must be typed and submitted via Blackboard.This assignment is due October 18, 2016  FACTUAL STATEMENTOnJanuary 5, 2016, Stella King was driving her 2016 Explorer on Main Street southof Eight Mile in the Township of Northville, the County of Wayne.  She was traveling southbound in the left laneof traffic.  Just as she passed the ConeyIsland, the right lane ended and the traffic from that lane was to merge withthe left lane. (Stella’s lane) Just as Stella was approaching the spot wherethe lanes merged, Donald Woods, driving a 2014 Jaguar XJ, pulled in front ofher without warning, hit her vehicle on the front side and caused her to losecontrol of her vehicle and drive off the road. Donald Woods was ticketed for careless driving, exceeding the speedlimit, and failure to use his turn signal.  Ms.King was taken to the hospital where she suffered a concussion, a broken arm,and collar bone, as well as numerous internal injuries, contusions andbruises.  She was kept in the hospitalfor one week and could not return to her job as a real estate broker for 2months.  Her doctors are uncertain if shewill ever have the complete use of her right arm again as it still continues tobe very painful.  So far her medicalbills exceed $50,000.00, and her very lucrative career (she reported over$200,000.00 per year to the IRS) is in jeopardy.The Elements of the Cause of Action For AutoNegligence:1. A person operating a motor vehicle hasa legal duty to exercise ordinary and reasonable care while operatingthe vehicle on a road, highway, or a place open to the public;2. If a person breaches the duty;and 3. damages result; and4. the breach of the duty is the proximatecause of the damages then that person may be liable for personal injuryauto negligence.Will provide a sample if needed. Must be suffiecient and correct!