Complaint for Negligence

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Submitted By calivbmnky
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STATE OF CALIFORNIA SOLANO COUNTY CIRCUIT COURT
SANDRA ELMORE and
BOB ELMORE,
Plaintiffs Civil Action, File No. 1234
v.
RAMBLER AMERICAN INC and
MISSION INC Defendants Plaintiff Demands Trial by Jury
COMPLAINT FOR NEGLIGENCE
Plaintiffs Sandra Elmore and Bob Elmore bring forth the following causes of action and allege the following: 1. The jurisdiction of this court is based on Plaintiffs being citizens of Vallejo, California in the county of Solano and the amount in controversy in the action which is more than $2,500. 2. Plaintiff Sandra Elmore is a teacher and homemaker who resides at 100 Galaxy Drive, Vallejo, in Solano County, California. 3. Plaintiff Bob Elmore is the husband of Sandra Elmore and resides with her. 4. Defendant Rambler American Inc. is incorporated in the state of Delaware, with its principal place of business located at 15000 Rambler Way, Vallejo, California. 5. Defendant Mission Inc. is incorporated in the state of Delaware with its principal place of business at 500 Main Street, Vallejo, California. 6. On March 16, 1962 plaintiffs Sandra Elmore and Bob Elmore purchased a 1962 Rambler American station wagon from Mission. 7. Defendant Mission Inc. serviced the vehicle at approximately 1,500 miles had been driven. Mission Inc. changed the oil, changed the oil filter, and lubricated the vehicle. 8. After the vehicle was serviced by Mission Inc. Plaintiff, Sandra Elmore noticed a shimmy when driving between 60 and 65 miles per hour. Plaintiff Bob Elmore drove the vehicle and could barely detect any shimmy in the vehicle. 9. On the bright clear afternoon of April 29, 1962 Plaintiff Sandra Elmore was driving the vehicle when the accident occurred. Plaintiff was driving south on a three lane road near Northridge in Solano County. 10. The Rambler had been driven 2,751 miles before…...

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