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Date: Today's Date To: Paralegal From: Roy Saunders, Attorney Re: Complaint in Arkansas Bus Collision Case I need you to draft a complaint in the

Date: Today's Date To: Paralegal From: Roy Saunders, Attorney Re: Complaint in Arkansas Bus Collision Case

I need you to draft a complaint in the Arkansas Bus Collision Case. We represent the parents of one boy who was seriously injured in the collision. The child's name is Michael Wiley (M.W.) and his parents are Brandon Wiley and Ellen Wiley. The boy, who was sitting in Seat 10A described in theNTSB report, sustained serious injuries, including multiple spinal fractures and a fractured right arm and leg. The boy has sustained more than $75,000 in damages and the extent of damages will be determined if the case goes to trial. Use the facts from the NTSB report when you draft the complaint. The boy and his parents are residents of Arkansas and reside at 1510 Willow Tree Lane, Mountainburg, Arkansas.

The complaint should be based on only one cause of action for negligence. Name only one defendant in the complaint, the trucking company, Gayle Stuart Trucking, Inc., a privately held company incorporated in the State of Missouri with its principal place of business being 504 Main Street, Vandalia, Missouri.

We should file the complaint in federal court in Arkansas for the U.S. District Court for the Western District of Arkansas. Jurisdiction in federal court is based on diversity of citizenship.

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