COMPLAINT

STATE OF SOUTH CAROLINA

COUNTY OF GREENVILLE

IN THE COURT OF COMMON PLEAS

COUNTY OF GREENVILLE

C.A. No.: 2019-CP-2306459

Erin Leigh Driggers, Plaintiff, v. Brittnee Sloane Brooks, Defendant.

Plaintiff, by and through her undersigned counsel of record will show unto this Honorable Court the following:

GENERAL ALLEGATIONS

1. Plaintiff Erin Leigh Driggers (hereinafter “Plaintiff”) is a citizen and resident of Pickens County, South Carolina.

2. Defendant Brittnee Sloane Brooks (hereinafter “Defendant”) is, upon information and belief, a citizen and resident of Pickens County, South Carolina.

3. The collision that gives rise to this action occurred in Greenville County, South Carolina.

4. This Honorable Court has jurisdiction of the parties and subject matter of this action, and venue is proper.

5. On or about December 6, 2016 at approximately 4:15 PM, Plaintiff, driving a 2016 Ram Truck, was traveling north on US 25. Defendant, while driving a 2004 Mazda attempted to make a left turn on US 25 from S 1018. Defendant failed to yield the right of way and pulled out directly in front of Plaintiff, causing a collision.

6. As a direct and proximate result of the collision, Plaintiff suffered injuries and damages as set forth hereinbelow.

PLAINTIFF’S CAUSE OF ACTION

(NEGLIGENCE)

7. Plaintiff incorporates herein by reference each and every allegation set forth hereinabove as if repeated verbatim.

8. Defendant, at the time and place in question, was negligent, grossly negligent and reckless in the following particulars, to wit:

(a) In failing to keep a proper lookout;

(b) In driving while distracted;

(c) In failing to stop, swerve, slow down or take other evasive action to avoid the collision;

(d) In failing to yield the right of way;

(e) In failing to act as a ordinary and prudent driver would have acted under the circumstances then and there existing.

9. As a direct and proximate result of the aforementioned acts of negligence, gross negligence and reckless ness on behalf of Defendant, Plaintiff suffered injuries to her person, including injuries to her neck and back that required expensive medical care and treatment.

10. As a further direct and proximate result of the aforementioned acts of negligence, gross negligence and recklessness on behalf of Defendant, Plaintiff endured pain, suffering and loss of enjoyment of life.

WHEREFORE, Plaintiff prays for judgment against Defendant for actual damages and, if warranted by facts learned through discovery, punitive damages in amount to be determined by the court at the trial of this case, for the costs of this action, and for such other and further relief as this honorable Court deems just and proper.

HARRISON WHITE, PC

s/ Wes A. Kissinger

Wes A. Kissinger

S.C. Bar No.: 13949

178 West Main Street (29306)

P. O. Box 3547 (29304)

Spartanburg, South Carolina

(864) 585-5100

Attorneys for Plaintiffs

November 7, 2019

Spartanburg, South Carolina

Dec. 11, 18, 25

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