Assume that you work for attorney Tara Jolans of Adams & Tate, 1000 Town Center,

Suite 500, White Tower, Michigan. Jolans has decided to represent Sandra Nelson in

her lawsuit against David Namisch. Based on the following information and the

material in the chapter, draft a complaint to be filed in the U.S. District Court for the

Eastern District of Michigan.

Sandra Nelson is the plaintiff in a lawsuit resulting from an automobile accident.

Sandra was turning left at a traffic light at the intersection of Jefferson and Mack

Streets while the left-turn arrow was green. In the intersection, she was hit from the

side by a 2014 Toyota Camry driven by David Namisch, who failed to stop at the

light. The accident occurred on June 3, 2016, at 11:30 p.m. David lives in New York,

was visiting his family in Michigan, and just prior to the accident had been out

drinking with his brothers. Several witnesses saw the accident. One of the witnesses

called the police.

Sandra was not wearing her seat belt at the time of the accident, and she was thrown

against the windshield, sustaining massive head injuries. When the police and

ambulance arrived, they did not think that she would make it to the hospital alive, but

she survived. She wants to claim damages of $500,000 for medical expenses, $65,000

for lost wages, and $75,000 for property damage to her Mercedes. The accident was

reported in the local newspaper, complete with photographs