ST. LOUIS — A woman is suing an employer and its driver, citing alleged insufficient measures were taken to prevent injuries.

Danette Berry filed a complaint July 25 in the St. Louis Circuit Court against Jonathan Wayne Skaggs and Landvatter Ready Mix Inc., alleging Skaggs negligently failed to slow down, stop or swerve the vehicle to avoid a collision.

According to the complaint, the plaintiff alleges that on May 1, 2015, she sustained serious injuries to her neck and shoulder, which caused her to suffer severe physical pain and incur medical expenses. The plaintiff holds Skaggs and Landvatter Ready Mix responsible because Skaggs allegedly failed to sound a horn or give any warning of his approach and improperly used a lane, allowing his vehicle to enter the plaintiff's lane of travel.

The plaintiff seeks damages in excess of $25,000 and cost expended for this action. She is represented by Thomas Traube of Sorrell & Traube in St. Louis.

St. Louis Circuit Court Case number 1722-CC10860

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