Dale M Ronad

IN THE CIRCUIT COURT FOR DAVIDSON COUNTY, TENNESSEE

DALE M. RONAD

Plaintiff

vs.

HERMAN SHULMAN

Defendant

COMPLAINT

COUNT 1

NEGLIGENCE

1. Plaintiff Dale M. Ronad, a minor, resident of Davidson County, Nashville, Tennessee who resides at 2413 Valley Crest Drive, Nashville Tennessee 37201, sues the defendant Herman Shulman, a resident of Davidson County. On information and belief he resides next door to the plaintiff Dale M. Ronad.

2. Comes the Plaintiff Dale M. Ronad, a minor, resident of Davidson County, Nashville, Tennessee, sues the Defendant Herman Shulman, a resident of Davidson County, Nashville, Tennessee, in a cause of action for damages in the sum of Twenty Five Thousand Dollars ($25,000) and for cause of action would show:

3. That the Plaintiff Dale M. Ronad was one and half years old on date of incident June 29, 1993 when he was attracted to a riding mower, being driven by the Defendant Herman Shulman. The Plaintiff approached the mower from the rear of the Defendant and the mower struck his toes causing serious injury

4. That the act of negligence by the Defendant Herman Shulman as stated herein were the direct and proximate cause of the injuries that Plaintiff Dale M. Ronad, sustained and that under the facts herein set out, the Defendant Herman Shulman is liable to the Plaintiff for all injuries and damages.

5. WHEREFORE, the plaintiff Dale M. Ronad praise for judgment in the amount of $25,000 against defendant Herman Shulman and any and all other relief the Court deems just and proper in the circumstance.

8-28-14

Robert W. Mitchel

Attorney for the Plaintiff

804 Stahlman Building

Nashville, TN 37201

(615) 955-5555