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The vehicle must be insured to be legally driven on public roads of Maryland. Failure to obey traffic control devices If the title specifies the purchase price, this document won’t be necessary.Unreasonable operation of a vehicle under conditions existing.Failure to reduce speed to avoid collision.Failure to give full time and attention.That on the occasion in question the Defendant, John Smith, was negligent in the following particulars, among others, to-wit:.That the Defendant, John Smith, negligently operated, maintained and controlled said automobile by failing to come to a stop behind the plaintiff so as to cause his vehicle to collide into the back of the vehicle being operated by the Plaintiff, Jane Doe.That on or about January 2, 2008, at approximately 8:00 a.m., the Defendant, John Smith, was operating a vehicle, a 2004 Nissan Pathfinder, directly behind the plaintiff traveling on Ivy Lane in Prince George’s County, Maryland.
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That on or about January 2, 2008, at approximately 8:00 a.m., the Plaintiff, Jane Doe, was operating her vehicle, a 2000 Nissan Maxima, on Ivy Lane in Prince George’s County, Maryland attempting to make a left turn.That it is believed and therefore alleged that the Defendant, John Smith, is an adult resident of Prince George’s County, Maryland.The Plaintiff, Jane Doe, is an adult resident of Prince George’s County, Maryland.
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IN THE CIRCUIT COURT FOR PRINCE GEORGE’S COUNTY, MARYLANDĬOMES NOW the Plaintiff, Jane Doe, by and through her attorneys, FORAN & FORAN, P.A., and sues the Defendant, John Smith, and for reasons therefore states as follows: