Assume that you work for attorney Tara Jolans of Adams & Tate, 1000 Town Center, Suite 500, White Tower, Michigan, 49600. Jolans has decided to represent Sandra Nelson in her lawsuit against David Namisch. Based on the following information and the material in the chapter, draft a complaint to be filed in the U.S. District Court for the Eastern District of Michigan.



Sandra Nelson is a plaintiff in a lawsuit resulting from an automobile accident. Sandra was turning left at a traffic light at the intersection of Jefferson and Mack Streets, while the left-turn arrow was green, when she was hit from the side by a 2014 Toyota Camry driven by David Namisch, who failed to stop at the light. The accident occurred on Friday, June 3, 2016, at 11:30 P.M. David lives in New York, was visiting his family in Michigan, and just prior to the accident had been out drinking with his brothers. Several witnesses saw the accident. One of the witnesses called the police. Sandra was not wearing her seat belt at the time of the accident, and she was thrown against the windshield, sustaining massive head injuries. When the police and ambulance arrived, they did not think that she would make it to the hospital alive, but she survived. She wants to claim damages of $500,000 for medical expenses, $65,000 for lost wages, and $55,000 for property damage to her Mercedes. The accident was reported in the local newspaper, complete with photographs.