Homer and Marge Sims were passengers in a car accident in Wildwood, NJ. Homer suffered severe injuries when their car was hit by a tour bus, driven into a storefront, and had a sign fall on the car. They are suing the bus driver, tour company, store owner, and city traffic department. Homer claims medical bills, lost wages, and suffering. Marge claims loss of marital services. They allege the bus driver was negligent, the store sign was loose, and the traffic lights were malfunctioning.

1. WALDMAN & SHAPIRO, P.C.
By: Justin P. Waldman, ESQ.
312 Seymour St.
Montclair, N.J. 07042
(973) 227-4738
Attorneys for Plaintiffs
_________________________________
SUPERIOR COURT OF NEW JERSEY
HOMER SIMS AND MARGE SIMS, LAW DIVISION – ESSEX COUNTY
DOCKET NO.
Plaintiffs,
Civil Action
V.
RAYMOND MEADS AND BET YOUR COMPLAINT AND JURY DEMAND
DOLLAR TOURS, FRANK’S
SURFBOARD SHOP, AND CITY OF
WILDWOOD TRAFFIC
DEPARTMENT,
Defendants,
_________________________________
The plaintiffs, Homer and Marge Sims, residing at 2136 Canterbury Court, in the
City of Maplewood, County of Essex, State of New Jersey, complaining of the
Defendants say that:
FIRST COUNT
1. On or about September 3, 2007, the Plaintiff, Homer Sims was driving his
2006 BMW 726I, with the plaintiff, Marge Sims, being a passenger in the front seat, in a
northerly direction on Maine Street at or near its intersection with Vermont Street,
stopped at a red light, at or about 8:00 P.M., in the City of Wildwood, County of Cape
May, State of New Jersey.

2. 2. A few minutes ago, when Defendant Raymond Meads was driving a bus as an
employee for Defendant Bet Your Dollar Tours; he was stopped by the Wildwood Police
and given a ticket for speeding and running a red light.
3. A few minutes later, when Plaintiff Homer Sims proceeded through the
intersection of Main Street and Vermont Street as the traffic light turned green,
Defendant Raymond Meads was driving his bus fifty miles per hour and was negligent by
not stopping his bus quickly enough as he hit the side of Plaintiff’s car.
4. As a result of Defendant Raymond Meads’ Bus hitting Plaintiff Homer Sims’
car, the collision caused the Plaintiff’s car to be thrown to the side of Defendant Frank’s
Surfboard Shop, where the sign from the shop fell on top of the roof of Plaintiff Homer
Sims’ car and thus caused the roof to cave in on him.
5. As a result of such collision and caving in of the roof of the car, Plaintiff
Homer Sims suffered severe painful bodily injuries including a broken collar bone, a
broken arm, two broken legs, facial contusions, and partial paralysis in his mid section.
6. As a result of such injuries, Plaintiff Homer Sims has experienced extreme
pain and suffering, inability to pursue his usual course of employment, job loss, loss of
wages, and outstanding medical bills not covered by insurance.
Wherefore, Plaintiff Homer Sims, demands judgment against the Defendants,
Raymond Meads and Bet Your Dollar Tours, together for damages and costs for this suit.

3. SECOND COUNT
1. Plaintiff Marge Sims is the wife of Plaintiff Homer Sims.
2. Plaintiff Marge Sims repeats the allegations of the First Count herein in their
entirety.
3. As a result of the injuries suffered by her husband as aforesaid, Plaintiff Marge
Sims has and will in the future suffered the loss of services of her husband such as his
ability to take out the garbage, mow the lawn, shovel the snow, carry the groceries and
perform other marital duties and she will be required to provide special services and care
to him.
Wherefore, Plaintiff Marge Sims, demands judgment against the Defendants,
Raymond Meads and Bet Your Dollar Tours, together for damages and costs for this suit.
THIRD COUNT
1. Plaintiff Homer Sims repeats the allegations of Paragraphs 1, 2, 3, 4 of the
First Count herein.
2. As a result of such collision, Plaintiff Homer Sims’ car was severely damaged
requiring him to pay bills for touring and storing and for transportation costs incurred for
transporting him and his wife to and from the doctors.
Wherefore, Plaintiff Homer Sims, demands judgment against the Defendants,
Raymond Meads and Bet Your Dollar Tours, together for damages and costs for this suit.

4. FOURTH COUNT
1. Plaintiff Homer Sims repeats the allegations of the First Count and
incorporating the same into this count as if set forth at length herein.
2. The Defendant, Frank’s Surfboard Shop, is located on the intersection of
Maine Street and Vermont Street in the City of Wildwood.
3. The sign for the Defendant, Frank’s Surfboard Shop, was loosely secured to
the building, thereby creating a dangerous and hazardous condition.
4. The Defendant, Frank’s Surfboard Shop, should have known that the
dangerous condition created a reasonably foreseeable risk or injury to the traveling
public.
5. The Defendant, Frank’s Surfboard Shop, was under a duty to take reasonable
action to tighten the screws of the sign securely onto the building.
6. The Defendant, Frank’s Surfboard Shop, failed and neglected to take any
action to tighten the screws of the sign securely onto the building.
7. As a direct and proximate result of the loose sign falling on top of the car due
to the impact of the car hitting the building, Plaintiff Homer Sims suffered severe painful
bodily injuries including a broken collar bone, a broken arm, two broken legs, facial
contusions and partial paralysis in his mid section.

5. 8. As a result of such injuries, Plaintiff Homer Sims has experienced extreme
pain and suffering, inability to pursue his usual course of employment, job loss, loss of
wages, and outstanding medical bills not covered by insurance.
Wherefore, Plaintiff Homer Sims, demands judgment against the Defendant,
Frank’s Surfboard Shop, for damages and costs for this suit.
FIFTH COUNT
1. Plaintiff Marge Sims is the wife of Plaintiff Homer Sims.
2. Plaintiff Marge Sims repeats the allegations of the Fourth Count herein in
their entirety.
3. As a result of the injuries suffered by her husband as aforesaid, Plaintiff Marge
Sims has and will in the future suffered the loss of services of her husband such as his
ability to take out the garbage, mow the lawn, shovel the snow, carry the groceries and
perform other marital duties and she will be required to provide special services and care
to him.
Wherefore, Plaintiff Marge Sims, demands judgment against the Defendant,
Frank’s Surfboard Shop, for damages and costs for this suit.
SIXTH COUNT
1. Plaintiff Homer Sims repeats the allegations of Paragraphs 1, 2, 3, 4, 5, 6 of
the Fourth Count herein.

6. 2. As a direct and proximate result of the loose sign falling on top of the car due
to the impact of the car hitting the building, Plaintiff Homer Sims’ car was severely
damaged requiring him to pay bills for touring and storing and for transportation costs
incurred for transporting him and his wife to and from the doctors.
Wherefore, Plaintiff Homer Sims, demands judgment against the Defendant,
Frank’s Surfboard Shop, for damages and costs for this suit.
SEVENTH COUNT
1. Plaintiff Homer Sims repeats the allegations of the First Count and
incorporating the same into this count as if set forth at length herein.
2. The intersection of Main Street and Vermont Street in the City of Wildwood
is controlled by traffic lights owned, operated, and maintained by the Defendant, City of
Wildwood Traffic Department.
3. Two weeks prior to September 3, 2007, the Defendant, City of Wildwood
Traffic Department, was given notice that the traffic lights on the intersection of Maine
Street and Vermont Street were malfunctioning because both of the light signals would
indicate green at the same time, thereby creating a dangerous and hazardous condition.
4. The Defendant, City of Wildwood Traffic Department, had actual and
constructive notice of the failure of the traffic signal equipment and knew or should have
known that the dangerous condition created a reasonably foreseeable risk or injury to the
traveling public.

7. 5. The Defendant, City of Wildwood Traffic Department, was under a duty to
take reasonable action to guard travelers until repairs to the lights could be made.
6. The Defendant, City of Wildwood Traffic Department, failed and neglected to
take any action to guard the traveling public or to repair the defective lights in a
reasonable diligent fashion.
7. As a direct and proximate result of the faulty traffic light signals, Plaintiff
Homer Sims suffered severe painful bodily injuries including a broken collar bone, a
broken arm, two broken legs, facial contusions, and partial paralysis in his mid section.
8. As a result of such injuries, Plaintiff Homer Sims has experienced
extreme pain and suffering, inability to pursue his usual course of employment, job loss,
loss of wages, and outstanding medical bills not covered by insurance.
9. On November 3, 2007, Plaintiff Homer Sims served a Notice of Claim for his
damages in the form prescribed by N.J.S.A. 59:8-4 and signed by the Plaintiff, by mailing
the same certified mail, return receipt requested to the Defendant, City of Wildwood
Traffic Department.
10. More than six months have passed since the service of Plaintiff’s Notice of
Claim and the claim of Plaintiff Homer Sims remain unsatisfied.
Wherefore, Plaintiff Homer Sims, demands judgment against the Defendant,
City of Wildwood Traffic Department, for damages and costs for this suit.

8. EIGHTH COUNT
1. Plaintiff Marge Sims is the wife of Plaintiff Homer Sims.
2. Plaintiff Marge Sims repeats the allegations of the Seventh Count herein in
their entirety.
3. As a result of the injuries suffered by her husband as aforesaid, Plaintiff Marge
Sims has and will in the future suffered the loss of services of her husband such as his
ability to take out the garbage, mow the lawn, shovel the snow, carry the groceries and
perform other marital duties and she will be required to provide special services and care
to him.
4. On November 3, 2007, Plaintiff Marge Sims served a Notice of Claim for
damages in the form prescribed by N.J.S.A. 59:8-4 and signed by the Plaintiff, by mailing
the same certified mail, return receipt requested to the Defendant, City of Wildwood
Traffic Department.
5. More than six months have passed since the service of Plaintiff’s Notice of
Claim and the claim of Plaintiff Marge Sims remain unsatisfied.
Wherefore, Plaintiff Marge Sims, demands judgment against the Defendant,
City of Wildwood Traffic Department, for damages and costs for this suit.
NINTH COUNT
1. Plaintiff Homer Sims repeats the allegations of Paragraphs 1, 2, 3, 4, 5, 6 of
the Seventh Count herein.

9. 2. As a direct and proximate result of the faulty traffic light signals, Plaintiff
Homer Sims’ car was severely damaged requiring him to pay bills for touring and storing
and for transportation costs incurred for transporting him and his wife to and from the
doctors.
Wherefore, Plaintiff Homer Sims, demands judgment against the Defendant,
City of Wildwood Traffic Department, for damages and costs for this suit.
JURY DEMAND
Plaintiffs demand trial by jury of 12 persons on all issues.
WALDMAN & SHAPIRO, P.C.
Attorneys for Plaintiffs
by_____________________
Justin P. Waldman, ESQ.
A Member of the Firm

10. CERTIFICATION PURSUANT TO R. 4.5-1
1. I hereby certify that to my knowledge the matter in controversy is not the
subject of another action pending in any court or of a pending arbitration proceeding.
2. To my knowledge, there have been no previous actions in this State respecting
this action.
3. To my knowledge, no other judicial action or arbitration procedure is
contemplated in this State, except for the current complaint.
4. I have no knowledge at this time of the names of any other party who should
be joined in this action.
WALDMAN & SHAPIRO, P.C
Attorneys for Plaintiffs
by_____________________
Justin P. Waldman, ESQ.
A Member of the Firm
Dated: September 5, 2007