Cummings Manookian has dedicated and skillful car accident lawyers ready to take on your case and obtain a maximum monetary recovery for your loss of property, pain and suffering.

1. IN THE CIRCUIT COURT FOR DAVIDSON COUNTY, TENNESSEE
)
)
Plaintiff, )
) CASE NO. 16C-_______
v. )
) Jury Demand (12)
RANDALL DORAN, )
)
Defendant. )
COMPLAINT
The Plaintiff, states for this cause of action as follows:
The Parties
1. (“the Plaintiff”) is a citizen and resident of Davidson County,
Tennessee.
2. Randall Doran (“the Defendant”) was the driver of the vehicle that hit the
vehicle in which the Plaintiff was operating at the time of the July 29, 2015 car accident
referenced herein. The Defendant is a citizen and resident of Kingsport, Tennessee. At

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the time of the accident described herein, the Defendant lived at 253 Beulah Church
Rd., Kingsport, TN 37663.
3. The car accident described herein occurred in Davidson County,
Tennessee on July 29, 2015.
Preliminary Issues
4. This is a negligence action involving the July 29, 2015 car accident that
involved the parties. This car accident occurred in Davidson County, Tennessee. The
accident occurred at the intersection of Hwy 31 and Division St. in Nashville,
Tennessee.
5. This lawsuit was filed within the applicable statute of limitations.
6. Venue and jurisdiction are appropriate with this Court.
7. The Defendant was properly served with this lawsuit and the Complaint.
8. Tennessee law applies to this matter.
Facts and claims
9. On July 29, 2015, the parties were involved in a car accident. The accident
occurred as a result of the Defendant negligently driving the motor vehicle that the

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Defendant was operating into the vehicle that the Plaintiff was operating. The
Plaintiff’s vehicle was properly stopped in traffic when the Defendant drove the
Defendant’s vehicle into the back of the Plaintiff’s vehicle and caused the impact. The
Defendant’s negligence caused the accident, which resulted in physical injuries and
medical expenses.
10.The Plaintiff did nothing to negligently cause the accident.
11.The accident occurred as a result of the Defendant’s negligence, including,
but not limited to, not keeping a careful watch, and not driving carefully.
12.As a matter of law, the Defendant violated Tenn. Code Ann. section 55-8-
136(b) by failing to operate a motor vehicle with due care, by not keeping a safe
lookout, and by not devoting full time and attention to operating a motor vehicle, all of
which, in part or in combination, caused the car accident. The Defendant’s violations
of these statutory provisions constitute negligence per se, to which the Defendant is
liable to the Plaintiff for all resulting injuries and damages the Plaintiff sustained,
because the Plaintiff is a member of the class of persons who these statutes exists to
protect.
13. The Plaintiff suffered injuries as a result of the accident, including physical
pain and suffering. These injuries included, but are not limited to, (1) a concussion
and (2) post-concussion headaches and light sensitivity. The Plaintiff has received
medical care for the injuries from the collision. The Plaintiff will have future physical
pain and suffering as a result of the injury.

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14. As a result of the care and treatment provided in response to the car
accident, the Plaintiff incurred medical expenses, all of which were reasonable and
necessary in amount, and which were caused by the car accident. These medical
bills are attached, and the documented charges are presumed to be necessary and
reasonable pursuant to Tenn. Code Ann. section 24-5-113.
15. As a result of the care and treatment provided in response to the car
accident, the Plaintiff lost income related to not being able to close on sales at the
end of July 2015 that he otherwise would have closed. Those lost sales caused the
Plaintiff to lose some income that would have been earned via commissions, and
caused the Plaintiff to lose some income that would have been earned for bonus /
incentive pay for sales closed by the end of July 2015 that were not closed during that
timeframe.
16. The Defendant’s negligence caused the car accident. The Defendant’s
negligence was the actual cause and proximate cause of the injuries and damages
to the Plaintiff. The Defendant is liable to the Plaintiff for the Plaintiff’s injuries and
damages.
WHEREFORE, the Plaintiff prays:
1. That service of process issue for the Defendant at the address listed above,
and which counsel for the Plaintiff will execute.
2. That the Plaintiff recover from the Defendant all of the following items:
A. Compensatory damages for the Plaintiff’s injuries, including, past
and future physical pain and suffering, past and future emotional
pain and suffering, lost income and lost earnings, and medical
expenses, in an amount up to $50,000.00;

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B. Prejudgment interest with regard to the medical expenses, lost
income, and lost earnings;
C. Postjudgment interest at the maximum rate allowed under
Tennessee law;
D. All recoverable costs in this action; and,
E. Any other relief which the Court determines to be just and proper.
WHEREFORE, the Plaintiff sues the Defendant for the damages outlined above,
pursuant to the terms of the facts, the claims, and Tennessee law.
Respectfully submitted,
Brian Cummings, #19354
Cummings Manookian PLC
45 Music Square West
Nashville, TN 37203
(615) 266-3333 – phone
(615) 266-0250 - fax
Attorney for the Plaintiff

6. AUTO ACCIDENT LAWSUIT
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www.cmtriallawyers.com
Top-Rated Trial Lawyers for Medical Malpractice, Personal Injury, and Auto Accident Claims
Cummings Manookian – 45 Music Square West, Nashville, Tennessee 37203
__________________________________________________________________________________________________________________________________________

7. AUTO ACCIDENT LAWSUIT
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www.cmtriallawyers.com
Top-Rated Trial Lawyers for Medical Malpractice, Personal Injury, and Auto Accident Claims
Cummings Manookian – 45 Music Square West, Nashville, Tennessee 37203
__________________________________________________________________________________________________________________________________________
Respectfully submitted,
Brian Cummings, #19354
Brian Manookian, #26455
Cummings Manookian PLC
45 Music Square West
Nashville, Tennessee 37203
(T) 615-266-3333
(F) 615-266-0250
bcummings@cummingsmanookian.com
bmanookian@cummingsmanookian.com
www.cmtrialattorneys.com
Attorneys for the Plaintiffs