IN THE CIRCUIT COURT OF
FAYETTE COUNTY,
WEST VIRGINIA
Gary Jennings v.
Demonica Parrish
Service Type:
Filer- Order of Publication
NOTICE TO: Demonica Parrish, A12 Prudence Road, Oak Hill, WV 25901
THE COMPLAINT WHICH IS ATTACHED TO THIS SUMMONS IS IMPORTANT AND YOU MUST TAKE IMMEDIATE ACTION TO PROTECT YOUR RIGHTS. YOU OR YOUR ATTORNEY ARE REQUIRED TO FILE THE ORIGINAL OF YOUR WRITTEN ANSWER, EITHER ADMITTING OR DENYING EACH ALLEGATION IN THE COMPLAINT WITH THE CLERK OF THIS COURT. A COPY OF YOUR ANSWER MUST BE MAILED OR HAND DELIVERED BY YOU OR YOUR ATTORNEY TO THE OPPOSING PARTY’S ATTORNEY:
David Kirkpatrick, 348 North Kanawha Street, Beckley, WV 25801
THE ANSWER MUST BE MAILED WITHIN 20 DAYS AFTER THIS SUMMONS AND COMPLAINT WERE DELIVERED TO YOU OR A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE MONEY OR OTHER THINGS DEMANDED IN THE COMPLAINT.
SERVICE:
7/6/2023 9:29:54 AM
Date
/s/ Travis W. Prince
Clerk
E-FILED 7/6/2023 9:29 AM
CC-10-2023-C-36
IN THE CIRCUIT COURT OF
FAYETTE COUNTY,
WEST VIRGINIA
GARY JENNINGS,
Plaintiff,
v.
DEMONICA PARRISH,
Defendant.
COMPLAINT
Comes now the Plaintiff, GARY JENNINGS, by counsel David Kirkpatrick of Kirkpatrick Law Office, PLLC to state the following as his complaint against the above-named Defendant:
STATEMENT OF FACTS
Jurisdiction
1. The conduct alleged herein occured within the geographical boundaries of Fayette County, West Virginia.
2. Accordingly, the cause of action arose in Fayette County, West Virginia, making venue proper pursuant to ยง W.Va Code 56-1-1(a)(1).
3. Plaintiff is and was all the times relevant to this complaint a resident of Fayette County at the time of the accident.
4. The Defendant is and was at all times relevant to this complaint a resident of Fayette County, West Virginia.
The Collision
5. On March 25, 2021, Plaintiff Gary Jennings and Defendant Demonica Parrish were involved in a two car accident.
6. Plaintiff Gary Jennings was the driver of a 1998 Dodge Ram pickup truck traveling on Oyler Avenue, in Oak Hill, Fayette County West Virginia.
7. Defendant Demonica Parrish was driving a 2020 Dodge Durango that was attempting to leave the ramp from US 19 onto Olyer Avenue, in Oak Hill, Fayette County West Virginia.
8. On the date of the accident, Defendant Demonica Parrish had a duty to operate and otherwise position her vehicle in such a manner as not to endanger the safety and convenience of the traveling public, to maintain her vehicle under control, to keep a proper lookout for oncoming traffic, and to obey all traffic control signals that directed her route of travel upon the public roadway.
9. Defendant Demonica Parrish breached those duties to the Plaintiff Gary Jennings by illegall, negligently, recklessly operating the 2020 Dodge Durango involved in this collision.
10. Defendant Domina Parrish failed to keep a proper lookout for oncoming traffic and attempted to enter the roadway at a time when it was not safe to do so.
11. Because of Defendant Demonica Parrish’s acts of negligence Plaintiff Gary Jennings has incurred damages and will incur in the future damages in an amount sufficient to satisfy the jurisdictional requirement of this Court.
PRAYER FOR RELIEF
Wherefore, Plaintiff Gary Jennings prays for damages in an amount sufficient to fully compensate him for the following:
A. Damages in the form of past and potentially future medical expenses;
B. Past and future pain suffering;
C. Permanent impairment;
D. Loss of enjoyment of life;
E. Diminution of value to his vehicle, and;
F. Any other relief that this Honoarble Court deems just and proper.
GARY JENNINGS
By Counsel
David A. Kirkpatrick, W.VA. Bar No.7186
Kirkpatrick Law Office, PLLC
348 North Kanawha Street
Beckley, WV 25801
(304) 254-2260