1. DEWEY, CHEETUM & HOWE
Lee Chetum, Esquire
Identification No. 28018
1700 Market Street, 12th Floor
Philadelphia, PA 19103
(215)-772-4658
_______________________________________
Donna Miller & Steven Miller, h/w : COURT OF COMMON PLEAS
37 Holiday Drive : PHILADELPHIA COUNTY
Bala Cynwyd, PA 19004 :
: CIVIL ACTION-LAW
:
v. :
: MOTOR VEHICLE CASE
Joseph Evans : THIS IS AN ARBITRATION CASE
37 Montgomery Drive : ASSESSMENT OF DAMAGES
Narbeth, PA 19072 : HEARING IS REQUIRED
:
_______________________________________ COURT TERM:
COMPLAINT-CIVIL ACTION
Personal Injury – Motor Vehicle Accident (2V)
1. Plaintiffs are Donna Miller (“Ms. Miller”) & Steven Miller (“Mr. Miller”),
husband and wife who reside at 37 Holiday Drive, Bala Cynwyd, PA 19004.
2. Defendant is Joseph Evans, who resides at 37 Montgomery Drive, Narberth,
PA 19072.
3. On or about November 30, 2011, Ms. Miller was the operator of a motor
vehicle which was stopped at a red light at the intersection of Lancaster Avenue and
Remington Road in Wynnewood, Pennsylvania when her motor vehicle was struck in the
rear violently and with great force, by a motor vehicle owned and operated by the
defendant, all of which caused Ms. Miller to suffer injuries and damages as are
hereinafter set forth.

2. 4. The said accident resulted solely from the negligence, carelessness and
recklessness of the defendant named herein, and was due in no matter whatsoever to any
act or failure to act on the part of Ms. Miller.
5. The negligence, carelessness and recklessness of the defendant included, but
was not limited to the following:
a. Operation of a motor vehicle in a reckless, careless and negligent
manner at an improper, excessive rate of speed under the
circumstances;
b. Failure to properly operate and control the said motor vehicle;
c. Disregard of the rules of the road and Statutes of the Commonwealth
of Pennsylvania and the Ordinances of the City of Philadelphia that
govern the operation of motor vehicles on the streets and highways;
d. Failure to have said motor vehicle under proper and adequate control
under the circumstances;
e. Operation of said motor vehicle without due regard of the point and
position of the Ms. Miller;
f. Failure to keep a due and proper lookout for other traffic on the street;
g. Failure to maintain a reasonable lookout for the presence of other
motor vehicles on the road;
h. Failure to apply the brakes of said motor vehicle so as to avoid
crashing into Ms. Miller’s vehicle;
i. Failure to observe that care and caution required under the
circumstances;

3. j. Operation of said motor vehicle at an excessive rate of speed under the
circumstances.
6. As a result of the negligence, carelessness and recklessness of the defendant
aforementioned; Ms. Miller suffered injuries which are or may be serious and
permanent, including but not limited to the following: bulging disc at C5-6;
dizziness; nausea; fractured rib; chronic neck pain; muscle spasm; cervical
strain and sprain; lumbar sprain.
7. As a further result of the above described negligence, carelessness and
recklessness of the defendant, Ms. Miller has incurred and probably will
continue to incur for an indefinite time in the future, various expenses for
medicine and medical care in and about an effort to cure himself of the said
injuries.
8. As a further result of the above described negligence, carelessness and
recklessness of the defendant, the Ms. Miller has been and probably will in the
future continue to be prevented from attending to her usual activities, duties,
occupations and avocations, and she has suffered, and probably will in the
future, continue to suffer loss of her earnings and earning capacity or power.
9. As a further result of the above described negligence, carelessness and
recklessness of the defendant, Ms. Miller has suffered severe physical pain,
mental anguish and humiliation, and she may continue to suffer same for an
indefinite time in the future, all to her great detriment and loss.
10. As a further result of the above described negligence, carelessness and
recklessness of the defendant, Ms. Miller has incurred significant financial

4. expenses and may hereafter continue to incur other financial expenses or
losses.
11. As a further result of the above described negligence, carelessness and
recklessness of the defendant, the said automobile of Ms. Miller was damaged
in and around the rear steal support beam, rear bumper, absorber, spoiler, face
bar and inner brackets. Said Ms. Miller was obliged to have her automobile
repaired and was deprived of its use.
WHEREFORE, Donna Miller demands judgment in her favor and against the
defendant, Joseph Evans, in an amount not in excess of Fifty Thousand
($50,000.00) Dollars.
Count II
StevenMiller v. Joseph F. Evans
12. Plaintiff Steven Miller incorporates by reference the allegations contained in
Paragraphs one through ten inclusive as if the same was set forth at length herein.
13. At all times relevant to matter set forth herein, Plaintiff, Steven Miller was
and is the husband of plaintiff Donna Miller.
14. As a result of the aforesaid accident, plaintiff Steven Miller has been, and may
continue to be deprived of the society, companionship, services and consortium of his
wife Donna Miller, all to his great detriment and loss.

5. WHEREFORE, plaintiff Steven Miller demands judgment in his favor and
against the defendant, Joseph Evans, in an amount not in excess of Fifty Thousand
($50,000.00) Dollars.
DEWEY, CHEETUM & HOWE
By:_______________________________
Lee Chetum, Esquire
Identification No. 28018
1700 Market Street, 12th Floor
Philadelphia, PA 19103
(215)-772-4658
Attorneys for Plaintiffs

6. VERIFICATION
Donna Miller, plaintiff herein, hereby verifies that the statements made in the
foregoing Answer & New Matter are true and correct to the best of his knowledge,
information and belief and make this verification subject to the penalties of 18 Pa.C.S. &
4904 relating to unsworn falsification to authorities.
_____________________________________
Donna Miller
Date: January 31, 2012

7. VERIFICATION
Steven Miller, plaintiff herein, hereby verifies that the statements made in the
foregoing Answer & New Matter are true and correct to the best of his knowledge,
information and belief and make this verification subject to the penalties of 18 Pa.C.S. &
4904 relating to unsworn falsification to authorities.
_____________________________________
Steven Miller
Date: January 31, 2012