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COMPLAINT AND PRAYER FOR JURY TRIAL Mary Ann Johnson, Plaintiff, by Laura G.

Zois, and Miller & Zois, LLC, her attorneys, sues the defendant, James C. Sexton, and in support, states as follows:

PREAMBLE
1. Mary Ann Johnson, Plaintiff, is a resident of Maryland. 2. James C. Sexton, Defendant, is a resident of Maryland. 3. The Defendant regularly visits and is engaged in business in Baltimore City, Maryland. 4. This action arises from an car accident which occurred on May 22, 2009 at the intersection of Maryland Route 152 and Rockord Road. Both are public roads in Maryland.

STATEMENT OF FACTS
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5. On May 22, 2009, the Plaintiff, Mary Ann Johnson, was carefully and prudently stopped in her motor vehicle on Route 152, when her vehicle was violently struck from behind by the Defendant. 6. At the same time, a motor vehicle operated by James C. Sexton, Defendant, was traveling, and smashed into the Plaintiffs vehicle, causing a car accident in which the Plaintiff sustained serious personal injuries.

COUNT ONE
Plaintiff, Mary Ann Johnson realleges and incorporates by reference all those facts and allegations in paragraphs 1 through 6 above and further alleges: 7. The collision was caused by the recklessness, carelessness and negligence of the Defendant, James C. Sexton, for that among other acts and omissions the Defendant:

a. operated the motor vehicle at a high, dangerous and excessive rate of speed under the circumstances then and there existing; b. failed to reduce speed to avoid a collision; c. failed to observe due care and precaution and to maintain proper and adequate control of the motor vehicle; d. failed to keep a proper lookout for other vehicles lawfully upon the highway; e. failed to exercise reasonable care in the operation of the motor vehicle under the circumstances then and there existing; and f. In other respects not now known to the Plaintiff but which may become known Prior to or at the time of trial. 8. As a direct and proximate result of the negligence and carelessness of the Defendant, the Plaintiff: a. suffered serious, painful and permanent bodily injuries, great physical pain and mental anguish, severe and substantial emotional distress, loss of the capacity for the enjoyment of life; b. was, is and will be required to undergo medical treatment and to incur medical costs and expenses in order to alleviate injuries, pain and suffering; c. was, is and will be precluded from engaging in normal activities and pursuits, including a loss of ability to earn money and of actual earnings; d. and, otherwise was hurt, injured and caused to sustain losses. 9. All of the Plaintiff's losses were, are and will be due solely to and by reason of the carelessness and negligence of the Defendant, James C. Sexton, without any negligence or want of due care on the Plaintiff's part contributing thereto. WHEREFORE, this Plaintiff claims ONE MILLION FIVE HUNDRED THOUSAND DOLLARS ($1,500,000.00) in damages. Respectfully submitted, MILLER & ZOIS, LLC ____________________________ Ronald V. Miller Miller & Zois, LLC 400 E Pratt St # 800 Baltimore, MD 20201 (410) 553-6000 (410) 760-8922 (Fax) Attorneys for Plaintiffs

MICHELLE JACKSON 1234 Mountain Drive Glen Burnie, Maryland 21601, Plaintiff, v. MARYLAND AUTOMOBILE INS FUND (MAIF)

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IN THE DISTRICT COURT OF MARYLAND FOR ANNE ARUNDEL COUNTY (Annapolis) CASE NO.: 0702-0000000-2005

Served on: Alfred W. Redmer, Jr. Insurance Commissioner 525 St. Paul Place Baltimore, Md 21202-2272, Defendants.

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************************************************* COMPLAINT Plaintiff, Michelle Jackson, (hereinafter referred to as the Plaintiff) by and through her attorneys Laura G. Zois and Miller & Zois, LLC brings suit against the Defendant, Maryland Automobile Insurance Fund (MAIF), and in support thereof states as follows:

COUNT I - BREACH OF CONTRACT - PIP BENEFITS 1. That at all times, the Defendant, MAIF, was a corporation licensed in the State of Maryland to provide insurance including, but not limited to, Personal Injury Protection (PIP) coverage. More Samples


2.

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That on or before October 7, 2003, the Defendant, MAIF provided a policy of insurance which included PIP coverage to Ally Marshall Jackson.

3.

That on October 7, 2003, the Plaintiff, Michelle Jackson, the mother of Ally Marshall Jackson, was a passenger in Ally Marshall Jacksons vehicle which was involved in a motor vehicle collision in the State of Maryland.

4.

That on October 7, 2003, the Plaintiff was living with her daughter, Ally Marshall Jackson at 1234 Mountain Drive, Glen Burnie Maryland 21061.

5.

That following the collision the Defendant, MAIF, forwarded counsel for the Plaintiff an Application for Benefits under the PIP policy.

6.

That on February 10, 2004, Plaintiff completed and signed the Application for Benefits and returned it to the Defendant, MAIF.

7.

That since February 10, 2004, the Plaintiff has demanded benefits due her under the PIP policy from the Defendant, but the Defendant has refused to pay same.

8. 9.

That said denial is without justification. That under Maryland Code, Section 19-508(c), payment of benefits that are not made within 30 days after the insurer receives satisfactory proof of claim, said benefits are overdue and shall bear simple interest at the rate of 1.5% per month. WHEREFORE, the Plaintiff demands judgment against the Defendant, MAIF in the amount of $1,935.00 plus costs, pre-judgment interest, and post-judgment interest as this Court deems appropriate. Respectfully submitted, MILLER & ZOIS, LLC

Laura G. Zois Empire Towers, Suite 1001 7310 Ritchie Highway Glen Burnie, Maryland 21061 (410)553-6000 (410)760-8922 (Fax) Attorney for the Plaintiff IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND * * v * CASE NO.: * CONECTIV ENERGY- Defendant * *************************************************
SANDY JENKINS - Plaintiff

COMPLAINT
Plaintiff, Sandy Jenkins, by and through their undersigned attorneys, Ronald V. Miller, Jr., and Miller & Zois, LLC, bring suit against Defendant Conectiv Energy and states as follows: 1. Plaintiff is a resident of Mt. Carmel, Pennsylvania.. 2. Defendant Conectiv Energy carries on regular and substantial business in Baltimore City, Maryland. 3. On July 3, 2004 at 11:05 p.m., at 13601 Philadelphia SB Avenue in Ocean City, Maryland, Plaintiff suffered serious and permanent injuries as the result of an explosion that occurred on Defendants electrical pole (Conectiv pole 62496/95862 located on the bay side of 135th Street).

4. The explosion caused a cylinder measuring two inches long and 3/8 inches wide to become imbedded in Plaintiffs right forearm.

COUNT I - Strict Liability-Defect in Design - Product Liability


Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 4 of this Complaint. 5. Defendant participated in sale and maintenance of a product. 6. Defendant maintained, installed and assembled the product which contained a defective condition because the design was defective and unsafe. 7. This design defect made the product unreasonably dangerous. 8. The system as assembled by Conectiv remained unchanged and was in the same condition at the time of the injury hereafter alleged. 9. As a direct and proximate cause of Defendants installation and maintenance of the defectively designed product, Plaintiff sustained permanent injury.

COUNT II - Negligent Design and/or Maintenance - Product Liability


Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 9 of this Complaint. 10. Defendant built and/maintained an electrical system that had a defective design or was defectively maintained. Accordingly, defendant owed a duty to Plaintiff that the system was designed and maintained in such a way that made the system safe for its intended purpose. 11. Defendant knew or should have known when building and maintaining this electrical system that it was designed defectively or maintained, creating a unreasonable risk of injury for to Plaintiff. 12. Plaintiff was negligent in failing to properly design, manufacture, install, maintain, and communicate the defect in the system to Plaintiff, creating a clear and immediate risk of serious injury. As a direct and proximate result, Plaintiff sustained serious injury.

COUNT III - Strict Liability-Abnormally Dangerous Activity - Products Liability


Plaintiff re-alleges and incorporates by reference the allegations contained in Paragraph 1 through 12 of this Complaint. 13. Defendants conduct in maintaining an electrical system in a public area constituted an abnormally dangerous activity which exposed Plaintiff to an unreasonable risk of harm. 14. At all relevant times, Defendant had control over the abnormally dangerous activity of maintaining the electrical system. 15. As set forth above, Plaintiff sustained injury as a direct and proximate cause of this unreasonably dangerous activity. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of FIVE MILLION DOLLARS ($5,000,000.00), plus interest, costs and any other relief this court deems appropriate. Respectfully submitted, MILLER & ZOIS, LLC

Ronald V. Miller, Jr. Laura G. Zois Empire Towers, Suite 615 7310 Ritchie Highway Glen Burnie, Maryland 21061 (410)553-6000 Counsel for Plaintiffs PLAINTIFFS REQUEST FOR JURY TRIAL Plaintiff pursuant to Maryland Rule 2-325, prays a trial by jury on all issues.