‘ MICHAEL K. JEANES Clerk of the Superior Court BY Helissa fatten, fiamty Date WW2013 Time 14:15:54
mediation fittflmt ‘E-i”‘“ CREE? MOE-G93??? fine”— Michael L. York, #015362 {Riflwfi’Lm Brian M. Torba, #028295 – mm – 1 WATTEL & YORK 30am 2 2175 North Alma School Road, #BlO? Chandler, Arizona 85224 3 (480) 222-2020; Fax (480) 899-2741 Email: [email protected] 4 Allorlieysfor Plaintiff 5 IN THE SUPERIOR COURT OF THE STATE OF ARIZONA 6 IN AND FOR THE COUNTY OF MARICOPA‘
7 BARBARA STtDHUM, No
‘cv2013-092799
COMPLAINT
8 _ Plaintiff, 9 VS.
10 LAURENEASHLEY HOPKINS, a Minor, by and through her next friend, SUSAN
H HOPKINS; LAUREN ASHLEY HOPKINS, individually; SUSAN HOPKINS and
12 THOMAS HOPKINS, husband and wife; DOES l—XX and BLACK & WHITE
13 CORPORATIONS I—V,
Tort/ Motor Vehicle
2l75 Nonh Alma School Rood, Suite B-lO7
Wonel & York
14 Defendants.
VVVVVVVVVVVVVVVV
15′ Plaintiff alleges as follows:
16 I.
17 . . . . . The events giving rise to the cause of action set forth herein occurred Within the County of
18 . . . . . . . . . Maricopa, State of Arizona, that this Court has Jurisdiction over the sub] ect matter and the parties
19 . . . . to this litigation.
20 I].
A T T O R N E Y S A T L A W Chandler, Arizona 85224
WATTEL&YORK
21 Thai Defendant, LAUREN ASHLEY HOPKINS, upon information and belief, at all times
22 , relevant hereto, was a minor.
23 Ill.
24 That Defendants, SUSAN HOPKINS and THOMAS HOPKINS, upon information and
25 belifif, was at all times relevant hereto married and was acting on behalf of and for the benefit of said
26217 5 North Alma School Road, Suite B~l07
Wottei & York
A T T O R N E Y S A T L A W Chandler, Arizona 85224
WATTEL&YORK
10 ll T2 13 14 15 16 17 18 19 20 21 22 23
24
25
26
Defendants’ marital community. IV.
That Defendants, SUSAN HOPKINS and THOMAS HOPKLNS, upon information and belief, are the parents of the minor, LAUREN ASHLEY HOPKINS, and thus are responsible for her actions.
V.
The “Doe” Defendants l-XX are each fictitious names to designate unknown parties who may have in some manner contributed to Plaintiff’s injuries and damages and are liable therefore. The true names for said Defendants are unknown to the Plaintiff at this time and leave of Court is sought to amend this Complaint to include their true names after they are discovered.
VI.
The “BLACK & WHITE CORPORATIONS” Defendants l—V are each fictitious names to designate unknown companies and/or corporations and/or partnerships who may have in some manner contributed to Plaintiff’s injuries and damages and are liable therefore. The true names for said Defendants are unknovm to the Plaintiff at this time and leave of Court is sought to amend this Cemplaint to include their true names after they are discovered.
VII.
That on or about May 29, 2012 at or near south Priest Drive and West Grove Parkway in Tempe, Arizona, Defendant, LAUREN ASHLEY HOPKINS, operated and/or maintained a vehicle in a negligent manner and with reckless disregard of the rights and feelings of the Plaintiff, thereby causing damage to the Plaintiff.
VIII. Defendants, SUSAN HOPKINS and THOMAS HOPKINS, negligently entrusted a vehicle
to their minor child.
IX. Upon information and belief, Defendants SUSAN HOPKINS and THOMAS HOPKINS,2175 North Almc: School Road, Suite 8-107
Wottel & York
A T T O R N E Y S A T L A W Chondler,Arizono 85224
WATTEL&YORK
provided the vehicle involved in the subject coliision for general use by members of the family
including Defendant LAUREN ASHLEY HOPKINS. Therefore, Defendants SUSAN HOPKINS and
2 . . THOMAS HOPKINS are vicariously liable for any harm that is caused by or related to the use of 3 . . . the vehicle under the F amily Purpose Doctrine. 4 X. 5 . That as a result of Defendants conduct as stated ab0ve, Plaintiff, BARBARA STEDHUM, 6 sustained permanent personal injuries, which have caused pain, suffering and inconvenience; has 7 incurred expenses for medical care which will continue; and has suffered a loss of earnings, which 8 will continue. Plaintiff asks leave to amend as necessary to conform to the proof regarding the exact 9 amount of said past and future losses. 10 XI. 11 . . . . . . . . . Damages herein exceed the minimum Jurisdictional limits of the Court. 12 XII. 1 3 That Defendant, LAUREN ASHLEY HOPKINS, may now be an adult and therefore subject M to suit individually. 1 5
WHEREFORE, Plaintiff, BARBARA STIDHUM, prays for judgment against the
16 Defendants, as follows:
17 1. For such sums as and for general damages as may be fair and just.
1 8 2. For those special damages incurred to date, plus those future special damages proved at
19 . ~ the time of trial.
20 3. For costs of suit herein; and,
21 4. For such other and further relief as the Court deems just and proper.
22 . . DATED this id day ofMarch, 201
23 24 25
26