2000 Nissan Frontier Defective Seat Back Causes Spinal and Head Injuries
SUPERIOR COURT OF CALIFORNIA
COUNTY OF LOS ANGELES
JAKLIN MIKHAL
ROMINE,
Plaintiff,
vs.
NISSAN MOTOR CO., LTD.; NISSAN NORTH AMERICA, INC.; NISSAN DESIGN
AMERICA, INC.; THE ESTATE OF CHRISTOPHER RORY CLARK, DECEASED; DIANE KORNMANN
and DOES 1 through 100, inclusive,
Defendants.
_____________________________________
CASE
NO:BC386031
COMPLAINT FOR DAMAGES FOR:
1. Strict Product Liability
2. Negligent Product
Liability
3. Negligence and Negligent Entrustment
DEMAND FOR JURY TRIAL
COME NOW Plaintiff JAKLIN
MIKHAL ROMINE for causes of action against defendants, alleges as
follows:
COMMON ALLEGATIONS FOR ALL CAUSES OF ACTION
1. At all times Plaintiff JAKLIN MIKHAL ROMINE has been a
citizen and resident of the City of Alhambra, County of Los Angeles, State of
California.
2. At all times mentioned herein, Defendant NISSAN MOTOR
CO., LTD., was and is a Limited Liability Company, organized and existing under
the laws of the nation of Japan with a principal place of business in the City
of Tokyo, Japan.
3. At all times mentioned herein, Defendant
NISSAN NORTH AMERICA, INC., was and is a corporation duly organized and existing
pursuant to the laws of the State of California, with a principal place of
business in the City of Gardena, County of Los Angeles, State of California.
4. At all times mentioned herein, Defendant NISSAN DESIGN
AMERICA, INC., was and is a corporation duly organized and existing pursuant to
the laws of the State of Delaware, with a principal place of business in the
City and County of San Diego, State of California.
5. At all times mentioned herein Defendants, CHRISTOPHER RORY
CLARK, DECEASED and DIANE KORNMANN were and are citizens and residents of the
County of Los Angeles, State of California.
6. At all times mentioned herein, Defendants, DOES 1 through
100, and each of them, were individuals, corporations, partnerships, and/or
associations residing in and/or authorized to and/or doing business in the State
of California.
7. The true names and/or capacities, whether individual,
corporate, associate, governmental or otherwise of Defendants DOES 1
through 100, inclusive, and each of them are unknown to the Plaintiff, who
therefore sues said defendants by such fictitious names. When the true
names and/or capacities of said defendants are ascertained, the Plaintiff will
seek leave of this Court to amend the Complaint accordingly.
8. Plaintiff is informed and believes, and based thereupon
alleges, that each defendant designated herein as a Doe was responsible,
negligently or in some other actionable manner, for the events and happenings
herein referred to which proximately caused the damages to Plaintiff as
hereinafter alleged, either through said defendant’s own negligence or through
the conduct of its agents, servants, employees or representatives in some other
manner.
9. Plaintiff is informed and believes and based thereupon
alleges that at all times mentioned herein the defendants were the agents,
servants, employees, representatives and/or joint venturers of their
co-defendants and were, as such acting within the course, scope and authority of
said agency, services, employment, representation and/or joint venture in that
each and every defendant, as aforesaid when acting as principal, was negligent
in the selection and hiring of each and every other defendant as an agent,
servant, employee, representative and/or joint
venturer.
10. Plaintiff is informed and believes, and based
thereupon alleges that at all times mentioned herein each of the defendants,
including Defendants DOES 1 through 100, inclusive, and each of them were the
agents, servants, employees, representatives of each of the remaining defendants
and were at all times material hereto acting within the authorized course and
scope of said agency, service, employment and/or representation, and/or that all
of said acts, conduct and omissions were subsequently ratified by their
respective principals and the benefits thereof accepted by such principals.
11. At all times mentioned herein, Defendants, NISSAN MOTOR
CO., LTD., NISSAN NORTH AMERICA, INC., NISSAN DESIGN AMERICA, INC., and DOES 1
through 100, inclusive, were and are engaged in the business of manufacturing,
fabricating, designing, assembling, distributing, selling, inspecting,
servicing, repairing, marketing, warranting, leasing, renting, selling,
retailing, wholesaling and advertising a certain subject 2000 Nissan Frontier,
California License Plate No. 7X97019, Vehicle Identification No.
1N6ED27T5YC327636, (hereinafter the “SUBJECT VEHICLE”) and each and every
component part thereof, which defendants knew, or in the exercise of reasonable
care should have known, would be used without inspection for defects in its
parts, mechanisms or design, for use in the State of California and
elsewhere.
12. On or about October 21, 2006, while at all times properly
using her available seat belt and shoulder restraints, Plaintiff JAKLIN MIKHAL
ROMINE was driving the SUBJECT VEHICLE, in the City of Pasadena, in the County
of Los Angeles, in the State of California. Plaintiff was stopped in the
number one lane of eastbound Corson Street for the red light at Lake Avenue and
Corson Street. While she was stopped at the intersection, her vehicle was rear
ended by another vehicle, causing her to hit the vehicle in front of her. When
her vehicle was rear ended, Plaintiff’s seat broke and collapsed rearward,
permitting her body to submarine backward and underneath her seat belt and
shoulder restraints, in turn causing the Plaintiff’s head to strike the rear
passenger seat back seat, causing catastrophic and permanent spinal and head
injuries, permanently rendering Plaintiff a paraplegic.
FIRST CAUSE OF
ACTION
(Strict Product Liability against Defendants
NISSAN MOTOR CO.,
LTD., NISSAN NORTH AMERICA, INC., NISSAN DESIGN
AMERICA, INC., and DOES 1
through 100, inclusive)
13. Plaintiff re-alleges and incorporates by reference each
of paragraphs 1 through 12, above, as though fully set forth
herein.
14. Defendants, NISSAN MOTOR CO., LTD., NISSAN NORTH
AMERICA, INC., NISSAN DESIGN AMERICA, INC., and DOES 1 through 100, inclusive,
and each of them, knew that the SUBJECT VEHICLE was to be purchased and used
without inspection for defects by the users of that vehicle including but not
limited to Plaintiff.
15. The SUBJECT VEHICLE, and each of its component
parts, were manufactured, designed, assembled, packaged, tested, fabricated,
analyzed, inspected, merchandised, marketed, distributed, labeled, advertised,
promoted, sold, supplied, leased, rented, repaired, adjusted, and selected by
each of the defendants, with inherent vices and defects both in design and
manufacturing (hereinafter “SUBJECT DEFECTS”), and by their failure to warn of
the SUBJECT DEFECTS of which they were at all times aware, which SUBJECT DEFECTS
made the SUBJECT VEHICLE and each of its component parts, dangerous, hazardous
and unsafe both for its intended use or for reasonably foreseeable misuses.
16. These SUBJECT DEFECTS included, but were not
limited to the
following:
A. Defective
and unsafe seats and seat backs, which failed to perform during the accident
sequence, causing the Plaintiff’s head to be forced back into the rear passenger
compartment and causing her body to slide off the front seat, submarine/ramp up
and back over the seat and be thrown into the back seat, breaking her neck,
rendering Plaintiff a paraplegic. At all times prior to their manufacturer of
the SUBJECT VEHICLE, defendants knew and were well aware, from both prior
accidents, lawsuits, and warranty claims, and from mandatory pre-production fuel
system integrity tests required by law to be conducted under Federal Motor
Vehicle Safety Standard (“FMVSS”), 49 C.F.R. § 571.301, that the SUBJECT
VEHICLE’s seat backs were too weak and were incapable of withstanding
foreseeable, modest, rear-end impacts at closure speeds as low as 30 miles per
hour, without collapsing and causing catastrophic injuries to
properly-restrained occupants. Despite the availability of simple methods
to correct the defects, as recommended on information and belief by defendants’
own automotive engineers including, but not limited to, strengthened seat back
frames, stronger recliners, dual recliners, and belt-integrated seats, and in
spite of the known risk of serious and fatal head and spinal injuries and
occupant ejection, defendants chose to ignore the inherent safety problem, and
took no action to prevent such debilitating injuries and deaths, because of
concern solely over cost penalties, including increased production costs and
reduced profits.
B. A
defective and unsafe restraint system, which defendants and each of them knew
and were aware, from prior accidents, incidents, claims, lawsuits, warranty
claims, other media publications, and from their own FMVSS 301 fuel system
integrity test, that would fail to restrain an occupant in the SUBJECT VEHICLE
in the event of a rear impact event, following known and foreseeable collapse of
the front seat back rearward and which, in this case, failed to restrain
Plaintiff, allowing her to ramp up and over the seat, breaking the head rest and
rendering it ineffective, and throwing the Plaintiff into the back seat during
the accident sequence, breaking her neck and rendering her a
paraplegic.
C. Inadequate
and/or lack of any warnings regarding the above defects.
17. Said SUBJECT VEHICLE, and each of its component
parts was unsafe for its intended use and reasonably foreseeable misuses by
reason of the defects in its design and/or manufacturing and/or failure to warn
by said defendants, and each of them, in that when the SUBJECT VEHICLE and each
of its component parts was used by Plaintiff, on or about October 21, 2006, as
intended or in a reasonably foreseeable manner, the SUBJECT VEHICLE, during a
reasonably foreseeable rear end impact event, was dangerous and defective, and
the driver’s seat and seat back broke, rendering the restraint system totally
ineffective, and forcing Plaintiff’s body to catapult backwards, breaking her
neck and causing serious head and neck injuries to Plaintiff, legally resulting
in Plaintiff’s damages as set forth herein.
18. As a direct and legal result of the conduct of
defendants, and each of them, and the defects inherent in the vehicle, serious
personal injuries were caused thereby to Plaintiff, causing her to suffer
serious physical and mental injuries to her body and mind, all in turn legally
resulting in Plaintiff’s special and general damages in a sum in excess of the
minimum subject matter jurisdiction of this Superior Court according to proof at
trial.
19. As a further direct and legal result of the conduct of
defendants, and each of them, and the SUBJECT DEFECTS inherent in the SUBJECT
VEHICLE, each of its component parts and/or aftermarket parts and/or
installation guides, Plaintiff has further suffered a loss of wages and earning
capacity, and will continue to suffer earnings and wage losses in the future,
according to proof at trial.
ALLEGATIONS SUPPORTING EXEMPLARY
DAMAGES PRAYER
ON FIRST AND SECOND CAUSES OF ACTION, BY PLAINTIFF, Against
Defendants NISSAN MOTOR CO., LTD., NISSAN NORTH AMERICA, INC., NISSAN DESIGN
AMERICA, INC, and DOES 1 through 100, inclusive
20. Plaintiff is further informed and believes and thereon
alleges that Defendants NISSAN MOTOR CO., LTD., NISSAN OF NORTH AMERICA, INC.,
NISSAN DESIGN AMERICA, INC., and DOES 1 through 100, and each of them
intentionally engaged in conduct which, with respect to the SUBJECT DEFECTS,
which Plaintiff alleges was a legal cause of her losses, damages, injuries and
harm, exposed Plaintiff and other users of the SUBJECT VEHICLE to the risks of
death and catastrophic injuries arising from potential dangers known to the
defendants, in order to advance the defendants’ pecuniary interests and thus
acted with a conscious disregard for the safety of the Plaintiff and other users
of the SUBJECT VEHICLE, warranting an award of exemplary damages against
Defendants NISSAN MOTOR CO., LTD., NISSAN NORTH AMERICA, INC., NISSAN DESIGN
AMERICA, INC, and DOES 1 through 100, pursuant to California Civil Code § 3294
c)(1), and the rule enunciated in Ford Motor Co. v. Home Ins. Co. (1981) 116
Cal. App.3d 374, 381-382 and PPG Industries, Inc v. Transamerica Ins. Co. (1996)
49 Cal. App.4th 1120. The facts supporting the defendants’ intentional conduct
which exposed the Plaintiff and other users of the SUBJECT VEHICLE to serious
potential danger known to the defendants in order to advance the defendants’
pecuniary interests, are on information and belief, as
follows:
A. Defendants and
each of them, have known since the early 1970's, that most of their vehicles’
front seat backs, when the seats are occupied, are so weak and
poorly-reinforced, such that they can and do collapse rearward and will strike
the rear seats in a 30-35 mile per hour rear end collision. In February,
1992, CBS aired a nationwide “60-Minutes” segment, of which defendants were at
all times aware, which exposed this problem with defendants’ (and other
U.S. automaker’s) seats, as well as recounting the stories of several accident
victims whose seats had collapsed in moderate speed rear-end collisions leading
to deaths and catastrophic injuries. Also featured in the “60-Minutes”
presentation was an interview with Mercedes-Benz’ executives who pointed out
that their vehicles’ seats were not permitted to collapse during such rear-end
impacts, and that such performance “would be considered as unacceptable.”
Recognizing that 30 mile per hour rear end collisions are quite commonplace on
American’s roads, yet concerned over a rash of Ford Pinto and Chevrolet Vega gas
tank explosions during such moderate rear end impacts, in 1976 the National
Highway Traffic Safety Administration (“NHTSA”) enacted Federal Motor Vehicle
Safety Standard (“FMVSS”) 301, which required that all automakers selling
automobiles in the U.S. conduct documented, filmed and/or videotaped rear end
barrier impact crash testing of all of their vehicle platforms, to ensure proper
fuel system integrity during such accidents.
B. The films of these FMVSS 301 tests
reveal that virtually all of defendants’ and their American competitor
automakers’ vehicles’ front seat backs in vehicles manufactured since the 301
tests were first required, failed and collapsed backward causing the test
dummies therein to strike the rear seats of its vehicles during these rear end
impact tests, a fact of which defendants were clearly aware. On
information and belief, defendants also knew from a 1979 New Car Assessment
Program Test (“NCAP”) conducted by NHTSA, that both front seats of their
vehicles would and did fail and collapse rearward, and Plaintiff is informed and
believes that defendants and/or their representatives dispatched one or more
teams of safety engineers to investigate these incidents, in which it had been
established that both crash test dummies occupying the vehicles’ front seats had
been propelled rearward striking the back seat of the
vehicle.
C. As a result of a flood
of letters from the public following the February 1992 “60-Minutes”
presentation, Plaintiff is informed and believes that defendants, their U.S.
competitor automakers, and their predecessors, all commissioned various Seat
Back Strength Task Forces comprised of numerous engineers, management and
in-house attorneys in an effort to look into the seat back failure issues as
well as to look into what defendants’ European competitors (including
Mercedes-Benz) were doing with regard to seat back
performance.
D.
Plaintiff is further informed and believes, and thereon alleges that since
the 1992 “60 Minutes” presentation and at all times prior to their manufacturer
of the SUBJECT VEHICLE, defendants knew and were well aware, from both prior
accidents, lawsuits, incidents, and warranty claims, from NHTSA hotline Vehicle
Owner Questionnaires (“VOQ’s”), and from mandatory pre-production fuel system
integrity tests required by law to be conducted under Federal Motor Vehicle
Safety Standard (“FMVSS”), 49 C.F.R. § 571.301, that the SUBJECT VEHICLE’s seat
backs were too weak and were incapable of withstanding foreseeable, modest,
rear-end impacts at closure speeds as low as 30 miles per hour, without
collapsing and causing death and serious catastrophic spinal and head injuries
to their occupants.
E. Plaintiff is
further informed and believes, and thereon alleges that, despite knowledge of
all of the foregoing, defendants knowingly and purposefully designed,
manufactured and installed, and continued to design, manufacture, and install
into the SUBJECT VEHICLE, such unsafe and defective passenger seats which they
knew would cause death and/or serious injuries to front seated occupants in
foreseeable and statistically inevitable rear-end impacts, and thus knowingly
and deliberately exposed properly-restrained occupants of their vehicles,
including Plaintiff as an occupant of the SUBJECT VEHICLE, to the risks of death
and serious injuries resulting from such foreseeable and inevitable rear-end
impacts all for the purposes of advancing defendants pecuniary interests,
i.e., avoidance of more costly components to enhance and improve seat back
strength, avoidance of more expensive but alternative amply feasible designs
(including, but not limited to, metallurgically stronger recliners, dual
recliners, stronger seat back frames, and belt-integrated seats -- any of which
would have prevented the Plaintiff’s catastrophic injuries in this case),
avoidance of increased production costs, avoidance of loss of profits, as well
as loss of customer confidence, loss of sales, and adverse publicity adversely
impacting defendants’ sales of many platforms of their vehicles using similar
seat back designs. In so intentionally exposing Plaintiff and other
members of the public to serious potential dangers of death and serious injuries
known to the defendants in order to advance defendants’ pecuniary interests, in
conscious disregard for the safety of the Plaintiff and other users of the
SUBJECT VEHICLE, defendants and each of them have acted despicably, because such
conduct could kill people, as enunciated in the case of Romo v. Ford Motor Co.
(2002) 99 Cal.App.4th 1115, 1141, expressly affirmed on all grounds except
federal Const’l issues at 113 Cal.App.4th 738
(2003).
F. Defendants’ conduct alleged
herein was despicable, because defendants knew and intended that their
purposeful design, manufacture, and installation into the SUBJECT VEHICLE
of such unsafe and defective passenger seats which they knew would cause
death and/or serious injuries to front seated occupants in foreseeable and
statistically inevitable rear-end impacts, could kill people and/or cause them
to suffer permanent, catastrophic injuries, such as those suffered by Plaintiff
as a result thereof.
G. Defendants
further acted despicably, by failing to warn Plaintiff and other members of the
public, of the risks of death and serious injuries resulting from the defective
and unsafe seats they knowingly and deliberately installed into the SUBJECT
VEHICLE, of which risks of death and serious injury defendants were at all times
well aware, and which defendants willfully and deliberately failed to warn for
the purposes of advancing defendants pecuniary interests, i.e., avoidance
of loss of vehicle sales and lost profits, as well as loss of customer
confidence, and adverse publicity adversely impacting defendants’ sales of many
platforms of their vehicles using similar seat back designs. In so
intentionally failing to warn Plaintiff and other members of the public of such
serious risks of death and serious injuries known to the defendants in order to
advance defendants’ pecuniary interests, defendants acted in conscious disregard
for the safety of the Plaintiff and other users of the SUBJECT VEHICLE.
21. Plaintiff further alleges that the conduct of the
defendants was undertaken with the result that the SUBJECT VEHICLE’s ultimate
defects in its design and production were fully intended by the defendants to
reside therein such that they were and are the product of the entire corporate
management and corporate policy of the defendants with respect to the conscious
willful and disregard of public safety for defendants’ pecuniary gain with
regard to the design, manufacture, production, and marketing of the SUBJECT
VEHICLE.
22. Plaintiff further alleges that the conduct of the
defendants was undertaken with the result that the SUBJECT VEHICLE’s ultimate
defects in its design and production were fully intended by the defendants to
reside therein. Plaintiff is informed and believes that the decisions made by
the defendants and each of them knowingly to design and manufacture the SUBJECT
VEHICLE with its defective seats and seat backs, its defective restraint system
and components, and failure to warn of these defects, all in the defective and
dangerous manner as alleged herein, were made by corporate management of the
defendants and each of them, by the product of corporate policy, in that such
major and strategic design and manufacturing decisions, by virtue of the
corporate structure of the defendants and each of them, could be made only at
the level of corporate management, as the product of corporate policy, given the
substantial capitalization requirements and risks associated with such high
level design and manufacturing decisions, across an entire vehicle platform line
for the SUBJECT VEHICLE, such that they were and are the product of the entire
corporate management and corporate policy of the defendants with respect to the
conscious and willful disregard of public safety for defendants’ pecuniary gain
regarding the design, manufacture, production, marketing and sale of the SUBJECT
VEHICLE.
23. As a direct and legal result of the aforementioned
conduct of defendants and each of them, an award of exemplary and punitive
damages against Defendants NISSAN MOTOR CO., LTD., NISSAN OF NORTH AMERICA,
INC., NISSAN DESIGN AMERICA, INC., and DOES 1 through 100, and each of them, is
proper and appropriate to punish said defendants and to deter such conduct in
the future.
SECOND CAUSE OF ACTION
(Negligence [Product
Liability] against Defendants
NISSAN MOTOR CO., LTD., NISSAN NORTH AMERICA,
INC., NISSAN DESIGN AMERICA, INC, and DOES 1 through 100,
inclusive)
24. Plaintiff incorporates, repeats and
re-alleges each and every allegation in paragraphs 1 through 23, above,
and incorporate the same by reference as though set forth in detail
herein.
25. At all times herein mentioned, defendants and each of
them, had a duty to use reasonable due care in the manufacture, design,
assembly, packaging, testing, fabricating, analysis, inspection, merchandising,
marketing, distributing, labeling, advertising, promotion, sale, supply, lease,
rental, warning, selection, inspection and repair of said SUBJECT VEHICLE and
each of its component parts.
26. At all times mentioned,
defendants and each of them, knew, and/or in the exercise of reasonable care
should have known, that said SUBJECT VEHICLE and each of its components parts
were not properly manufactured, designed, assembled, packaged, tested,
fabricated, analyzed, inspected, merchandised, marketed, distributed, labeled,
advertised, promoted, sold, supplied, leased, rented, repaired, selected and
provided inadequate warnings for the use and purpose for which it was intended
in that it was likely to injure the person who used said product, each of its
component parts and/or aftermarket parts and/or installation
guides.
27. Defendants, and each of them, so negligently and
carelessly, manufactured, designed, assembled, packaged, tested, fabricated,
analyzed, inspected, merchandised, marketed, modified, distributed, labeled,
advertised, promoted, sold, supplied, leased, rented, repaired, selected and
provided inadequate warnings and provided said SUBJECT VEHICLE and each of its
component parts so that the same was a defective and dangerous product, unsafe
and not crashworthy for the respective use and purpose for which it was intended
when used and driven as recommended or for reasonably foreseeable misuse by
members of the public, including the actions of that driver who hit Plaintiff
from behind in a reasonably foreseeable and statistically inevitable rear end
impact event. In particular, said SUBJECT VEHICLE and each of its
component parts during a reasonably foreseeable maneuver were dangerous and
defective in that the driver’s seat and seat back failed, rendering the
restraint system ineffective, causing severe injury to Plaintiff.
28. As a direct and legal result of the negligence,
carelessness, and unlawful conduct of the defendants, and each of them, and the
defects inherent in the vehicle, defendants legally caused the severe personal
injuries to the Plaintiff, all in turn legally resulting in Plaintiff’s damages
as set forth herein.
THIRD CAUSE OF ACTION
(Negligence and Negligent
Entrustment against Defendants
CHRISTOPHER RORY CLARK, DECEASED and DIANE
KORNMANN)
29. Plaintiff incorporates, repeats and re-alleges each and
every allegation in paragraphs 1 through 28 above and incorporates the same by
reference as though set forth in detail herein.
30. On or
about October 21, 2006, Defendant, DIANE KORNMANN, was the owner of a 2005
Nissan Altima, California License No. 5JFP610 (“ALTIMA”), and, by words or
conduct, gave permission to CHRISTOPHER RORY CLARK, DECEASED to use the
vehicle. CHRISTOPHER RORY CLARK, DECEASED carelessly, negligently, and
recklessly, struck the rear of the vehicle being operated by the
Plaintiff. CHRISTOPHER RORY CLARK, DECEASED was negligent in following the
Plaintiff's vehicle too closely and in failing to maintain a safe distance
between his vehicle and the vehicle being operated by the Plaintiff.
Defendant, DIANE KORNMANN, knew, or should have known, that CHRISTOPHER RORY
CLARK, DECEASED was incompetent or unfit to drive the ALTIMA, and failed to use
due care in negligently, carelessly, and recklessly entrusting the ALTIMA to
CHRISTOPHER RORY CLARK, DECEASED given the latter’s known incompetence and
unfitness to drive, which incompetence and unfitness was substantial factor in
causing the damages to the Plaintiff.
31. Pursuant to California Probate Code §§ 550 through 555,
Plaintiff seeks damages against Defendant THE ESTATE OF CHRISTOPHER RORY CLARK,
DECEASED within the limits and coverage of liability insurance.
32. As a direct, legal and proximate cause of the
negligence, carelessness and unlawful conduct of the Defendants, CHRISTOPHER
RORY CLARK, DECEASED and DIANE KORNMANN, and the defects inherent in the
vehicle, Plaintiff suffered severe personal injuries, legally resulting in
Plaintiff’s damages as set forth herein.
WHEREFORE, Plaintiff prays for
judgment against defendants and each of them, as follows:
1. For special
and economic damages including, past and future medical expenses, past and
future loss of income and future earning capacity, according to proof at
trial;
2. For general damages including damages for pain suffering,
physical and mental injuries, including serious emotional distress,
disfigurement, and loss of enjoyment of life;
3. For prejudgment
interest, as determined by and accrued according to applicable
statutes;
4. For costs of suit incurred herein; and
5. For any
other and further relief the Court deems just and proper;
6. Limits of
liability insurance, ONLY, AGAINST DEFENDANT THE ESTATE OF CHRISTOPHER RORY
CLARK, DECEASED, and ONLY on the Third Cause of
Action;
7. Exemplary and punitive damages, ONLY, AGAINST
DEFENDANTS NISSAN MOTOR CO., LTD., NISSAN NORTH AMERICA, INC., NISSAN DESIGN
AMERICA, INC., AND DOES 1 THROUGH 100, INCLUSIVE, and ONLY on the First and
Second Causes of Action.
DATED: November 18, 2009 BISNAR|CHASE
By:__________________________________
BRIAN D. CHASE,
Esq.
MIKE PEÑA, Esq.
Attorneys for Plaintiff JAKLIN MIKHAL ROMINE
DEMAND FOR JURY TRIAL
Plaintiff, JAKLIN MIKHAL ROMINE,
hereby demands a trial by jury.
DATED: November 18, 2009
BISNAR|CHASE
By:__________________________________
BRIAN D. CHASE,
Esq.
MIKE PEÑA, Esq.
Attorneys for Plaintiff JAKLIN MIKHAL ROMINE
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