COMPLAINT AND PRAYER FOR JURY TRIAL

Mary Ann Johnson, Plaintiff, by Laura G. Zois, and Miller & Zois, LLC, her attorneys, sues the defendant, James

C. Sexton, and in support, states as follows:

PREAMBLE

1. Mary Ann Johnson, Plaintiff, is a resident of Maryland.

2. James C. Sexton, Defendant, is a resident of Maryland.

3. The Defendant regularly visits and is engaged in business in Baltimore City, Maryland.

4. This action arises from an car accident which occurred on May 22, 2009 at the intersection of Maryland Route 152

and Rockord Road. Both are public roads in Maryland.

STATEMENT OF FACTS

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5. On May 22, 2009, the Plaintiff, Mary Ann Johnson, was carefully and prudently stopped in her motor vehicle on

Route 152, when her vehicle was violently struck from behind by the Defendant.

6. At the same time, a motor vehicle operated by James C. Sexton, Defendant, was traveling, and smashed into the

Plaintiff’s vehicle, causing a car accident in which the Plaintiff sustained serious personal injuries.

 

COUNT ONE

Plaintiff, Mary Ann Johnson realleges and incorporates by reference all those facts and allegations in

paragraphs 1 through 6 above and further alleges:

7. The collision was caused by the recklessness, carelessness and negligence of the Defendant, James C. Sexton,

for that among other acts and omissions the Defendant:

a. operated the motor vehicle at a high, dangerous and excessive rate of speed under the circumstances then and

there existing;

b. failed to reduce speed to avoid a collision;

c. failed to observe due care and precaution and to maintain proper and adequate control of the motor vehicle;

d. failed to keep a proper lookout for other vehicles lawfully upon the highway;

e. failed to exercise reasonable care in the operation of the motor vehicle under the circumstances then and there

existing; and

f. In other respects not now known to the Plaintiff but which may become known Prior to or at the time of trial.

8. As a direct and proximate result of the negligence and carelessness of the Defendant, the Plaintiff:

a. suffered serious, painful and permanent bodily injuries, great physical pain and mental anguish, severe and

substantial emotional distress, loss of the capacity for the enjoyment of life;

b. was, is and will be required to undergo medical treatment and to incur medical costs and expenses in order to

alleviate injuries, pain and suffering;

c. was, is and will be precluded from engaging in normal activities and pursuits, including a loss of ability to earn

money and of actual earnings;

d. and, otherwise was hurt, injured and caused to sustain losses.

9. All of the Plaintiff's losses were, are and will be due solely to and by reason of the carelessness and negligence of

the Defendant, James C. Sexton, without any negligence or want of due care on the Plaintiff's part contributing

thereto.

WHEREFORE, this Plaintiff claims ONE MILLION FIVE HUNDRED THOUSAND DOLLARS ($1,500,000.00) in

damages.

Respectfully submitted,

MILLER & ZOIS, LLC

____________________________

Ronald V. Miller

Miller & Zois, LLC

400 E Pratt St # 800

Baltimore, MD 20201

(410) 553-6000

(410) 760-8922 (Fax)

Attorneys for Plaintiffs

MICHELLE JACKSON1234 Mountain DriveGlen Burnie, Maryland 21601,

Plaintiff,v.

MARYLAND AUTOMOBILE INS FUND (MAIF)Served on:Alfred W. Redmer, Jr.Insurance Commissioner525 St. Paul PlaceBaltimore, Md 21202-2272,

* * * * * * * * * * * *

IN THE DISTRICT COURT OF MARYLAND

FOR ANNE ARUNDEL COUNTY (Annapolis)

CASE NO.: 0702-0000000-2005

Defendants.* *

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     Plaintiff, Michelle Jackson, (hereinafter referred to as the Plaintiff) by and through her attorneys Laura G. Zois and

Miller & Zois, LLC brings suit against the Defendant, Maryland Automobile Insurance Fund (MAIF), and in support

thereof states as follows:

COUNT I - BREACH OF CONTRACT - PIP BENEFITS

1. That at all times, the Defendant, MAIF, was a corporation licensed in the State of Maryland to

provide insurance including, but not limited to, Personal Injury Protection (PIP) coverage.

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2. That on or before October 7, 2003, the Defendant, MAIF provided a policy of insurance which

included PIP coverage to Ally Marshall Jackson.

3. That on October 7, 2003, the Plaintiff, Michelle Jackson, the mother of Ally Marshall Jackson, was

a passenger in Ally Marshall Jackson’s vehicle which was involved in a motor vehicle collision in

the State of Maryland.

4. That on October 7, 2003, the Plaintiff was living with her daughter, Ally Marshall Jackson at 1234

Mountain Drive, Glen Burnie Maryland 21061.

5. That following the collision the Defendant, MAIF, forwarded counsel for the Plaintiff an Application

for Benefits under the PIP policy.

6. That on February 10, 2004, Plaintiff completed and signed the Application for Benefits and returned

it to the Defendant, MAIF.

7. That since February 10, 2004, the Plaintiff has demanded benefits due her under the PIP policy

from the Defendant, but the Defendant has refused to pay same.

8. That said denial is without justification.

9. That under Maryland Code, Section 19-508(c), payment of benefits that are not made within 30

days after the insurer receives satisfactory proof of claim, said benefits are overdue and shall bear

simple interest at the rate of 1.5% per month.

WHEREFORE, the Plaintiff demands judgment against the Defendant, MAIF in the amount of

$1,935.00 plus costs, pre-judgment interest, and post-judgment interest as this Court deems

appropriate.

                                                                           Respectfully submitted,

                                                                           MILLER & ZOIS, LLC

                                                                           Laura G. Zois

                                                                           Empire Towers, Suite 1001

                                                                           7310 Ritchie Highway

                                                                           Glen Burnie, Maryland 21061

                                                                           (410)553-6000

                                                                           (410)760-8922 (Fax)

                                                                           Attorney for the Plaintiff

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

SANDY JENKINS - Plaintiff

vCONECTIV ENERGY- Defendant

* * * * *

         CASE NO.:

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COMPLAINT     Plaintiff, Sandy Jenkins, by and through their undersigned attorneys, Ronald V. Miller, Jr., and Miller & Zois, LLC,

bring suit against Defendant Conectiv Energy and states as follows:

      1. Plaintiff is a resident of Mt. Carmel, Pennsylvania..

      2. Defendant Conectiv Energy carries on regular and substantial business in Baltimore City, Maryland.

     3. On July 3, 2004 at 11:05 p.m., at 13601 Philadelphia SB Avenue in Ocean City, Maryland, Plaintiff suffered

serious and permanent injuries as the result of an explosion that occurred on Defendant’s electrical pole (Conectiv

pole 62496/95862 located on the bay side of 135th Street).

      4. The explosion caused a cylinder measuring two inches long and 3/8 inches wide to become imbedded in

Plaintiff’s right forearm.

COUNT I - Strict Liability-Defect in Design - Product Liability

     Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 4 of this

Complaint.

     5. Defendant participated in sale and maintenance of a product.

     6. Defendant maintained, installed and assembled the product which contained a defective condition because the

design was defective and unsafe.

     7. This design defect made the product unreasonably dangerous.

     8. The system as assembled by Conectiv remained unchanged and was in the same condition at the time of the

injury hereafter alleged.

     9. As a direct and proximate cause of Defendant’s installation and maintenance of the defectively designed

product, Plaintiff sustained permanent injury.

COUNT II - Negligent Design and/or Maintenance - Product Liability

     Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 9 of this

Complaint.

     10. Defendant built and/maintained an electrical system that had a defective design or was defectively maintained.

Accordingly, defendant owed a duty to Plaintiff that the system was designed and maintained in such a way that

made the system safe for its intended purpose.

     11. Defendant knew or should have known when building and maintaining this electrical system that it was

designed defectively or maintained, creating a unreasonable risk of injury for to Plaintiff.

     12. Plaintiff was negligent in failing to properly design, manufacture, install, maintain, and communicate the defect

in the system to Plaintiff, creating a clear and immediate risk of serious injury. As a direct and proximate result,

Plaintiff sustained serious injury.

COUNT III - Strict Liability-Abnormally Dangerous Activity - Products Liability

     Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 12 of this

Complaint.

     13. Defendant’s conduct in maintaining an electrical system in a public area constituted an abnormally dangerous

activity which exposed Plaintiff to an unreasonable risk of harm.

     14. At all relevant times, Defendant had control over the abnormally dangerous activity of maintaining the electrical

system.

     15. As set forth above, Plaintiff sustained injury as a direct and proximate cause of this unreasonably dangerous

activity.

     WHEREFORE, Plaintiff demands judgment against Defendant in the amount of FIVE MILLION DOLLARS

($5,000,000.00), plus interest, costs and any other relief this court deems appropriate.

                                                                                Respectfully submitted,

                                                                                MILLER & ZOIS, LLC

                                                                                Ronald V. Miller, Jr.

                                                                                Laura G. Zois

                                                                                Empire Towers, Suite 615

                                                                                7310 Ritchie Highway

                                                                                Glen Burnie, Maryland 21061

                                                                                (410)553-6000

                                                                                Counsel for Plaintiffs

PLAINTIFF’S REQUEST FOR JURY TRIAL

     Plaintiff pursuant to Maryland Rule 2-325, prays a trial by jury on all issues.