Background Information:

This assignment deals with a client of the law firm of P&K LLC. The client, Ms. Paula Harris retained P&K to represent her as plaintiff in a civil lawsuit resulting from an automobile accident in which she was involved and in which she sustained injuries. Assisting with the Harris case will require you to draft a complaint seeking the highest amount of compensation for client Harris' injuries.

Facts and Background of Client Harris Case: The accident in which Ms. Harris was involved occurred when the vehicle she was driving collided at an intersection with a vehicle driven by Officer Drew Preston of the Anne Arundel County, Maryland Police Department.

Ms. Harris suffered several physical injuries in the accident; Officer Preston's injuries were less serious.

We will refer to this incident at Collision at the Intersection.

Facts: The Incident: On February 17, 2018, at approximately 10 p.m., Officer Drew Preston was on duty conducting police patrols in his assigned marked patrol car. The patrol car was assigned to him by the Anne Arundel County Police Department (AACPD) and owned by the County.

He was driving on Crain Highway when he received a dispatch call to report to a burglary in progress.

After receiving the call, Officer Preston stated that he activated his patrol car emergency lights and siren. As he approached the intersection of Crain Highway and Hospital Drive, the traffic light at the intersection was red for persons traveling in the same direction. Officer Preston proceeded through and did not stop for the red light.

As he traveled through the intersection, he was caught off guard by Ms. Harris' vehicle traveling in the opposite direction. He tried to avoid colliding with her car but was not successful. He stated that he turned off his lights and siren after the collision and radioed for police and ambulance assistance.

Just prior to the accident, Paula Harris left a family dinner hosted at a relative's house. Ms. Harris stated that as she proceeded down Hospital Drive approaching the intersection with Crain Highway, the traffic light regulating her travel was red. She sat at the red light for approximately one and one-half minutes until the light turned green in her favor. There were no cars in front of her car. Ms. Harris stated that she proceeded to drive through the intersection.

She claimed she never heard or saw any police sirens or lights. While traveling through the intersection, her vehicle was hit by Officer Preston.

According to other officers at the scene, immediately following the collision, Ms. Harris complained of physical pain in her arm, rightside, and back. Officer Preston did not complain of any injuries at the time. The next morning, however, he felt pain in his neck and lower back. He went to see his doctor for treatment.

Ms. Harris' injuries consisted of a broken right arm, two fractured ribs, and pain in her neck. She was hospitalized for two days, and her medical bills totaled $178,000.

Ms. Harris is a resident of Alexandria, Virginia. Officer Preston is a resident of Columbia, Maryland, in Howard County.

Facts: Witnesses

Police Officer Vicki Zodin was in her police cruiser on Princeton Lane at its intersection with Crain Highway. She heard the dispatch call about the burglary in progress to which Offier Preston was called. However, Zodin was not on her way to the burglary call because she was in the process of transporting a prisoner. She saw Officer Preston driving down Crain Highway. She saw the emergency lights on his police car activated but does not recall hearing a siren. About twenty (20) seconds later, she heard a loud bang from the collision that occurred at the next intersection.

Officer Zodin immediately proceeded to the scene and waited for other officers and the ambulance to arrive.

Terence Wright and Trevor Williams were on Crain Highway near its intersection with Hospital Drive at the time of the collision. They were waiting at the traffic light. From the rear, they stated they saw the emergency lights of a police car, and then saw the lights go out prior to the police car passing them. A few seconds after the police car passed them, they saw the police car collide with another vehicle in the intersection. They stated they never heard police sirens.

Margaret Casey was in her car on Hospital Drive directly behind Ms. Harris' car while both cars waited at the traffic light at the time of the collision. Ms. Casey stated that she never saw any police lights or heard any sirens.

None of the witnesses to the collision could estimate how fast either Harris' car or Preston's car was traveling at the time of the accident.

Draft 25 Deposition Questions that you believe Ms. Harris will be asked at the time of her deposition. Make sure the questions are substantive & relevant to the claims Ms. Harris is making and any defenses that Officer Preston may be raising.