ST. LOUIS — An individual is suing Sarah N. Ramirez, a motor vehicle driver, for allegedly taking insufficient measures to prevent injuries.
Richard Kunkle filed a complaint on Feb. 9 in the St. Louis Circuit Court, alleging that the defendant breached her duty to operate a motor vehicle in a safe and careful manner.
According to the complaint, the plaintiff alleges that he was trick-or-treating with his two children on Oct. 31, 2016 when the defendant allegedly attempted to make a left turn and struck him with the bumper of her vehicle. The plaintiff claims that he sustained serious injuries to his right knee and leg, allegedly resulting in pain and suffering, emotional distress, lost wages and medical expenses. The plaintiff holds the defendant responsible for allegedly failing to obey traffic lights, keep a careful lookout and yield right of way.
The plaintiff requests a trial by jury and seeks judgment in his favor in an amount exceeding $25,000, plus punitive damages, costs and expenses and all other relief that is appropriate given the circumstances. He is represented by C. John Pleban, Lynette Petruska and J.C. Pleban of Pleban & Petruska Law LLC in St. Louis.
St. Louis Circuit Court case number 1822-CC00295