Pleadings/Complaint
IN THE CIRCUIT COURT FOR DAVIDSON COUNTY, TENNESSEE
DALE M. ROEHNIG, ) ) ) Plaintiff ) ) ) JURY DEMAND vs. ) ) No._________________ )
HERMAN A. SHULMAN, ) ) ) Defendant. )
COMPLAINT
COUNT I Comes the Plaintiff Dale M. Roehnig, a minor, resident of Davidson County, Nashville, Tennessee, sues the Defendant Herman A. Schulman, a resident of Davidson County, Nashville, Tennessee, in a cause of action for damages in the sum of Twenty Five Thousand Dollars ($25,000) and for cause of action would show: 1. That both the Plaintiff and the Defendant were residents of Davidson County, Nashville, Tennessee and lived next door to each other at 2413 Valley Crest Drive Nashville, TN 37201 on June 29, 1993. 2. That the Plaintiff Dale M. Roehnig was 1.5 years old on date of incident June 29, 1993 when he was attracted to a riding mower, being driven by the Defendant Herman A. Schulman. The Plaintiff approached the mower from the rear of the Defendant and the mower struck his toes causing serious injury. 3. 4. That the act of negligence by the Defendant Herman A. Schulman as stated herein were the direct and proximate cause of the injuries that Plaintiff Dale M. Roehnig sustained and that under the facts herein set out, the Defendant Herman A. Schulman is liable to the Plaintiff for all injuries and damages.
WHEREFORE, the Plaintiff Dale M. Roehnig, demands judgment against the Defendant Herman A. Schulman for damages in the sum of Twenty Five Thousand Dollars ($25,000) and further demands a jury to try this cause of action.
ROBERT W. MITCHELL (32112)
Attorney for the Plaintiff
804 Stahlman Building
Nashville, TN 37201
(615)
DALE M. ROEHNIG, ) ) ) Plaintiff ) ) ) JURY DEMAND vs. ) ) No._________________ )
HERMAN A. SHULMAN, ) ) ) Defendant. )
COMPLAINT
COUNT I Comes the Plaintiff Dale M. Roehnig, a minor, resident of Davidson County, Nashville, Tennessee, sues the Defendant Herman A. Schulman, a resident of Davidson County, Nashville, Tennessee, in a cause of action for damages in the sum of Twenty Five Thousand Dollars ($25,000) and for cause of action would show: 1. That both the Plaintiff and the Defendant were residents of Davidson County, Nashville, Tennessee and lived next door to each other at 2413 Valley Crest Drive Nashville, TN 37201 on June 29, 1993. 2. That the Plaintiff Dale M. Roehnig was 1.5 years old on date of incident June 29, 1993 when he was attracted to a riding mower, being driven by the Defendant Herman A. Schulman. The Plaintiff approached the mower from the rear of the Defendant and the mower struck his toes causing serious injury. 3. 4. That the act of negligence by the Defendant Herman A. Schulman as stated herein were the direct and proximate cause of the injuries that Plaintiff Dale M. Roehnig sustained and that under the facts herein set out, the Defendant Herman A. Schulman is liable to the Plaintiff for all injuries and damages.
WHEREFORE, the Plaintiff Dale M. Roehnig, demands judgment against the Defendant Herman A. Schulman for damages in the sum of Twenty Five Thousand Dollars ($25,000) and further demands a jury to try this cause of action.
ROBERT W. MITCHELL (32112)
Attorney for the Plaintiff
804 Stahlman Building
Nashville, TN 37201
(615)