(a) In failing to maintain a proper look-out; (b ) In failing to keep her vehicle under proper control; (c) In driving too fast for conditions; (d) In failing to apply her brakes; (@) In following to closely; (1 ) In falling to use the degree of care and caution that a reasonably prudent person would have used under the circumstances then and there prevailing: All of which were the direct and proximate cause of the injuries and damages suffered by the Plaintiff herein, said acts being in violation of the statutory laws of the State of South Carolina. 6. WHEREFORE, judgment is demanded against the Defendant and in favor of Plaintiff on the cause of action for such actual and punitive damages in each that a trier of fact may find, for the costs of this action, and for such other relief as the Court may deem just and proper. George Sink, P.A. Injury Lawyers By Joseph B. Fisher Attorneys for Plaintiff 7011 Rivers Avenue, Suite 105 P. O. Box 63506 N. Charleston, SC 29419-3506 (843) 569-1700 N Charleston, South Carolina Mayleth- 2019STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS COUNTY OF HAMPTON ) CASE NO.: 2011- CP25 - 206 FILED HERMAN MOYD MAY 17 2011 10:28am Plaintiffs, CLERK OF COURT HAMPTON COUNTY -VS- Complaint (TORT-AUTOMOBILE ACCIDENT) MONALISA RICE RIVERS (JURY TRIAL REQUESTED) Defendant. The Plaintiff, complaining of the Defendant above named, would respectfully show unto this Honorable Court: 1. Plaintiff is a citizen and resident of the County of Beaufort, State of South Carolina. 2. Defendant is upon information and belief, a citizen and resident of the County of Hampton, State of South Carolina. 3. On or about December 18, 2009 Plaintiff was traveling west on Lady's Island Drive in Beaufort, South Carolina. Plaintiff stopped for traffic and was rear-ended by the Defendant causing Plaintiff's vehicle to strike the car in front of him. 4. That as a further result, the Plaintiff suffered great physical harm and injury from being thrown about within the vehicle, all of which has and will in the future cause him to undergo much physical and mental pain and suffering, has and will in the future cause him to have to spend money for medical services and lose money in the nature of wages and earnings. 5. That the Defendant was negligent, wilful, wanton, careless, and grossly negligent at the time and place above-mentioned in the following particulars